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.

U.S.-U.K. Treaty Does Not Exempt U.K. Foundation from U.S.-Source Dividends Tax

The Internal Revenue Service Office of Chief Counsel, in a chief counsel advice memorandum released March 12, said the U.S.-U.K. income tax treaty does not exempt a U.K.-based private foundation from…