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…

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…

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…

IRS, Treasury Outline Intent to Issue Rules Stemming from ‘Subpart F Income Partnership Blocker’ Deal Transactions

Treasury and IRS indicate in Notice 2010-41 their intent to issue regulations to classify certain domestic partnerships as foreign for purposes of identifying the U.S. shareholders of a controlled foreign corporation that must include, in gross income…

Foreign Tax Credit Crackdown Seen as Possible Offset for Extenders Bill

House Ways and Means Committee member Chris Van Hollen (D-Md.) said May 5 lawmakers are looking at taxation of carried interest and a crackdown on misuse of the foreign tax credit as…

IRS Strongly Disagrees with Tax Court Ruling in Container Corp. Foreign Income Case, Weighs Next Steps

The Internal Revenue Service strongly disagrees with the U.S. Tax Court’s recent ruling in Container Corp. v. Commissioner that guaranty fees paid by a U.S. subsidiary to…

Government Prepares for Regulatory Push to Implement Rules on Foreign Financial Institution Reporting

The government is preparing for a major regulatory effort to implement broad new requirements for foreign financial institutions to report…

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…

Guaranty Fee Payments by U.S. Subsidiary to Mexican Corporation Analogous to Payments for Service, Tax Court Says

The U.S. Tax Court ruled in a Feb. 17 opinion that guaranty fees paid by a U.S. subsidiary to a Mexican corporation are analogous to payments for a service and are not…

Defense Contractors Avoided Taxes through Use of Foreign Affiliates, GAO Says

About one-third of the top 29 U.S. publicly traded defense contractors decreased their effective U.S. corporate tax rates in 2008 through the use of…