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…

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…

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…

Provisional Indemnification Receivables Includable in Foreign Insurer’s Subpart F Income, IRS Says

The Internal Revenue Service national office in Technical Advice Memorandum 201015030, released April 16, said provisional indemnification receivables (PIRs) for incurred but not…

Administration’s International Tax Proposals Stand-Alone Provisions, Not Package, Treasury International Tax Counsel Says

The international tax proposals in the Obama administration’s fiscal year 2011 budget should be viewed as individual provisions that can be included in legislation for…

Senate Moves to Codify Economic Substance Doctrine in Passing One-Year Extension of Tax Breaks

The Senate March 10 passed, 62-36, a one-year extension of $31 billion in popular tax breaks, while permanently codifying the economic substance doctrine and…

Senate to Bring $31 Billion Tax Extenders Measure to Floor During Week of March 1

Senate Democratic leaders announced Feb. 26 that they will bring a long-awaited bill featuring $31 billion in extensions of expired tax cuts to the Senate floor during the week of March 1.

Treasury Officials Defend Budget Proposal to Curb Abusive Transfer of Intangibles

Senior Treasury Department officials Feb. 24 defended an administration budget proposal intended to stop the abusive shifting of intangibles out of the United States, contending that…

Senate Majority Leader Reid’s Jobs Bill Gets Lackluster Reviews; Some Prefer Extending 2001, 2003 Tax Laws

Longer-term policies that give small businesses additional certainty about the tax climate in coming years may be better for the economy than…

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