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…

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…

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…

IRS Offers Guidance on New Reporting Requirements for U.S. Shareholders in Passive Foreign Investment Companies

The Internal Revenue Service April 6 offered interim guidance in Notice 2010-34 on newly enacted reporting requirements for U.S. shareholders in passive foreign investment companies under tax code Section 1298, with an effective date that one practitioner said will be welcome in the tax community.

IRS Chief Counsel Advice Addresses Interest Expense Allocable to Foreign Firm’s U.S. Insurance Business

The Internal Revenue Service Office of Chief Counsel, in a chief counsel advice memorandum released April 2, said a foreign taxpayer conducting a U.S. life insurance business must use the allocation method set forth in Treasury Regulations Section 1.882-5 to determine interest expense allocable to its U.S. branch for purposes of computing its U.S. income tax liability for 2001 and 2002 tax years.

Payments of U.S.-Source Income to Foreign Persons Skyrocketed Between 2005, 2007

Payments of U.S.-source income to foreign persons skyrocketed more than 70 percent between 2005 and 2007, with the vast majority of the payments going…

Firms Discuss Role of International Tax Policy, Effects Of Proposed Reform on Global Decisions

The tax function is only one of several factors that affect a company’s decision to conduct facets of its business in foreign countries, panelists said…

State Combined Reporting Regimes Pose Risks for Foreign Firms Without U.S. Presence

A foreign corporation that has no physical presence in the United States and no obligation to pay federal income taxes could nevertheless incur state tax liability in Massachusetts or Wisconsin under recently enacted combined reporting regimes, a panel of tax experts said Feb. 10.

ANALYSIS: New IRS Audit Guidelines Target Equity Swaps with Non-U.S. Counterparties

For more than 20 years, applicable Treasury regulations have provided that income from an equity swap, including dividend equivalent…

Treasury predicts major regulatory effort to implement anti-tax haven measure

Treasury Department officials said Dec. 10 that if the anti-tax haven Foreign Tax Compliance Act (H.R. 3933, S. 1934) is enacted, the government stands ready for a major regulatory effort to put it in place…