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IRS Hoping to Address Many Issues in First Guidance Under Foreign Account Tax Compliance Act

Internal Revenue Service Associate Chief Counsel Steven Musher June 3 said his agency is planning to include as many issues as it can in the first wave of guidance on legislation requiring broad…

BNA INSIGHTS: When the Other Shoe Falls: IRS Notice 2010-46 Restricts the Application of Notice 97-66 for Cross-Border Securities Loans

Notice 97-66 created an opportunity for non-U.S. financial institutions to participate in the securities lending markets for stocks of U.S. corporations without suffering…

Supreme Court Finds Federal Court Challenge to Ohio Tax Benefit Is Barred by Comity

The U.S. Supreme Court ruled June 1 that, under the comity doctrine, a federal lawsuit brought by retail natural gas suppliers that challenges Ohio’s natural gas taxation scheme as unconstitutional must…

Carried Interest Tax Hike Passes House in Tax Extenders Bill; Senate Outlook Unclear

The House voted 215-204 May 28 to extend dozens of popular tax cuts through the end of 2010 and raise taxes on investment fund managers and businesses with foreign income…

U.S., 14 Other Nations Sign OECD, Council of Europe Agreement on Cooperation in Tax Matters

Fifteen countries, including the United States, May 27 signed an update to a 1988 multilateral pact on administrative cooperation in tax matters that aims to provide a legal framework for…

International Revenue Raisers in Tax Extenders Bill Seen Constraining Foreign Tax Credit, Drawing Fire

The international revenue raisers in legislation (H.R. 4213) to extend expiring tax provisions would constrain the ability of U.S. multinationals to utilize the foreign tax credit and are…

Newly Codified Economic Substance Doctrine Could Mean More IRS Challenges, Practitioners Say

The newly codified economic substance doctrine may clear the way for Internal Revenue Service challenges to a broader range of transactions than before, tax practitioners said May 20…

Major Concerns Expressed by NY State Bar Association over House-Passed Curb on Tax Treaty Abuse

The New York State Bar Association Tax Section May 22 said it had “substantial and serious reservations” about a provision in House-passed jobs legislation (H.R. 4849) intended to stop…

Business Groups Oppose Tax Extenders Bill, Put Pressure on Democrats on Eve of House Vote

Business organizations May 24 lashed out against congressional Democrats’ tax extenders and jobs bill (H.R. 4213) set for House floor consideration, saying that its permanent tax increases on…

Practitioners Disappointed by Supreme Court’s Rejection of Petition to Review Textron Ruling involving Work Product Protection

Attorneys concerned about the work product protection issues raised in the Textron Inc. v. United States ruling by the U.S. Court of Appeals for the First Circuit told BNA they are…

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