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IRS Withdraws Guidance Implementing Cross-Border Securities Transaction Rules

The Internal Revenue Service May 20 issued Notice 2010-46, withdrawing 1997 guidance that generally limited the aggregate U.S. gross basis tax on a series of securities lending…

Chinese Bar Against PCAOB Inspections Poses Risk for U.S. Investors, Acting Chairman Says

Prohibitions against Public Company Accounting Oversight Board inspections of the work of auditing firms in China raise the possibility that, as more Chinese companies operate and file…

Tax Extenders Bill Seen Raising $11 Billion from Rules on Self-Employment Taxes

Congress’s proposed changes to the treatment of self-employment taxes on professional service providers are expected to raise $11.2 billion in new revenues for the federal government to help pay for…

BNA INSIGHTS: Did IRS Misuse ‘Step’ Doctrine in Revenue Ruling 2008-25?

Robert Willens, president of tax and consulting firm Robert Willens LLC, examines Revenue Ruling 2008-25, in which IRS concluded a transaction did not qualify as…

Senate Passes Financial Reform Bill Affecting Tax Treatment of Derivatives

The Senate voted 59-39 late May 20 to pass its version of a financial regulation reform bill that could have an adverse and unintended tax impact on…

New Bill Would Pull Back U.S. Tax Benefits for Foreign Multinational Companies

House Ways and Means Committee member Lloyd Doggett (D-Texas) May 18 unveiled legislation (H.R. 5328) to sharply pull back…

Manhattan District Attorney Announces Three Cases on Assets Hidden in Swiss Bank Accounts

Criminal charges have been filed against three New York City residents for falsifying personal income tax by hiding assets in secret Swiss bank accounts held at…

Securities Industry Group Seeks Swift Guidance on Treatment of New Equity Swaps Under HIRE Act Provision

The Securities Industry and Financial Markets Association May 11 asked the government for swift guidance on a newly enacted provision that would impose withholding tax on…

BNA INSIGHTS: Tax Liens: Treasury’s Uncertain Tax Position?

The Tax Court in a reviewed decision, Intermountain Insurance Service of Vail LLC v. Commissioner, rejected the Internal Revenue Service’s argument that a temporary regulation…

Tax-Writing Committee Chairmen Confident Carried Interest Treatment Change Can Pass Both Houses

The chairmen of both of Congress’s tax-writing committees said May 19 that negotiations over the annual tax extenders package have progressed to a point where they see that a change in the tax treatment of…

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