Carried Interest Tax Increase, S Corporation Curbs Softened in New Tax Extenders Proposal by Senate Finance Panel Chair Baucus

Senate Finance Committee Chairman Max Baucus (D-Mont.) June 16 introduced a new substitute amendment (S. Amdt. 4369) to the tax extenders bill (H.R. 4213) that would…

Senate Majority Leader Reid Seeks to Limit Debate, Pass Tax Extenders Legislation by Week’s End

Senate Majority Leader Harry Reid (D-Nev.) filed a motion June 14 to invoke cloture on the tax extenders bill (H.R. 4213) in an effort to complete the…

Permanent Establishment Can Be Created Through Agency Relationship, IRS Official Says

The activities of companies that send agents into other countries to do business can create a permanent establishment for tax purposes even if the presence of agents does not…

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…

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…

Government Still Looking at Asset Threshold Issue in Uncertain Tax Positions Proposal

The government continues to wrestle with the question of how a $10 million asset threshold for those required to disclose uncertain tax positions under a new proposal will apply to…

Administration Continues to Back Stand-Alone Use of International Tax Provisions, Senior Treasury Official Says

The administration continues to support the use of international tax proposals from its fiscal year 2011 budget as stand-alone provisions should Congress be inclined to do so, a senior Treasury…

IRS Official Predicts Scrutiny of Offshore Compliance, Transfer Pricing

Transfer pricing, withholding for nonresident aliens, and offshore compliance will be a major focus of scrutiny for the Internal Revenue Service in the global arena, new…

IRS Stressing Focus on Global Examinations, Seeking More Data on Taxpayers, KPMG Says

The Internal Revenue Service is intensifying its approach on audits of international issues, seeking increased information from taxpayers, and amping up not just…

Proposed Payment Card Reporting Rules Would Put U.S. Payers at Competitive Disadvantage, Witnesses Tell IRS

Witnesses at a March 15 Internal Revenue Service hearing on payments made to settle payment card and third-party network transactions focused on the foreign reporting requirements of …

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