U.S. Law Watch » Subpart F http://www.uslawwatch.com U.S. Legal & Regulatory Headlines Thu, 26 Jan 2012 18:07:29 +0000 en hourly 1 http://wordpress.org/?v=3.3.1 Carried Interest Tax Hike Passes House in Tax Extenders Bill; Senate Outlook Unclear http://www.uslawwatch.com/2010/06/01/tax/carried-interest-tax-hike-passes-house-tax-extenders-bill-senate-outlook-unclear/ http://www.uslawwatch.com/2010/06/01/tax/carried-interest-tax-hike-passes-house-tax-extenders-bill-senate-outlook-unclear/#comments Tue, 01 Jun 2010 15:47:11 +0000 admin http://www.uslawwatch.com/?p=2224

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, but the outlook for the bill in the Senate remains uncertain.

Senate leaders had been prepared to try to clear the American Jobs and Closing Tax Loopholes Act (H.R. 4213) ahead of Memorial Day, but difficulties in finding support among Democrats in both houses delayed action on the bill by more than a week (102 DTR G-7, 5/28/10). As a result, the Senate adjourned late May 27 and will not begin consideration of the extenders package until the week of June 7.

Even then, Senate Majority Leader Harry Reid (D-Nev.) said May 28 that there will be a series of amendments offered on the bill, possibly requiring the House to vote on the measure again ahead of Congress’s Independence Day recess (see related report in this issue)…

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]]> http://www.uslawwatch.com/2010/06/01/tax/carried-interest-tax-hike-passes-house-tax-extenders-bill-senate-outlook-unclear/feed/ 0 International Revenue Raisers in Tax Extenders Bill Seen Constraining Foreign Tax Credit, Drawing Fire http://www.uslawwatch.com/2010/05/27/tax/international-revenue-raisers-tax-extenders-bill-constraining-foreign-tax-credit-drawing-fire/ http://www.uslawwatch.com/2010/05/27/tax/international-revenue-raisers-tax-extenders-bill-constraining-foreign-tax-credit-drawing-fire/#comments Thu, 27 May 2010 11:15:52 +0000 admin http://www.uslawwatch.com/?p=2189

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 a major reason for the business community’s opposition to the bill, practitioners told BNA in interviews May 25 and 26.

Unveiled May 20, the American Jobs and Closing Tax Loopholes Act contains a host of pay-fors aimed at addressing perceived cross-border abuses (97 DTR GG-1, 5/21/10). House leaders said they plan to bring the extender legislation to the floor for a vote May 27 (see related report in this issue).

Both Joseph Calianno, Grant Thornton LLP, Washington, D.C., and Phil West, Steptoe & Johnson LLP, Washington, D.C., said in separate interviews that two key provisions, one dealing with covered asset acquisitions under tax code Section 338 and one addressing tax planning that uses a so-called “hopscotch” rule under Section 956, would limit use of the foreign credit and are a significant issue for corporate taxpayers.

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]]> http://www.uslawwatch.com/2010/05/27/tax/international-revenue-raisers-tax-extenders-bill-constraining-foreign-tax-credit-drawing-fire/feed/ 0 New Bill Would Pull Back U.S. Tax Benefits for Foreign Multinational Companies http://www.uslawwatch.com/2010/05/20/tax/bill-pull-tax-benefits-foreign-multinational-companies/ http://www.uslawwatch.com/2010/05/20/tax/bill-pull-tax-benefits-foreign-multinational-companies/#comments Thu, 20 May 2010 14:40:30 +0000 admin http://www.uslawwatch.com/?p=2109

House Ways and Means Committee member Lloyd Doggett (D-Texas) May 18 unveiled legislation (H.R. 5328) to sharply pull back…

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]]> http://www.uslawwatch.com/2010/05/20/tax/bill-pull-tax-benefits-foreign-multinational-companies/feed/ 0 IRS, Treasury Outline Intent to Issue Rules Stemming from ‘Subpart F Income Partnership Blocker’ Deal Transactions http://www.uslawwatch.com/2010/05/18/tax/irs-treasury-outline-intent-issue-rules/ http://www.uslawwatch.com/2010/05/18/tax/irs-treasury-outline-intent-issue-rules/#comments Tue, 18 May 2010 14:06:00 +0000 admin http://www.uslawwatch.com/?p=2057

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…

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]]> http://www.uslawwatch.com/2010/05/18/tax/irs-treasury-outline-intent-issue-rules/feed/ 0 Provisional Indemnification Receivables Includable in Foreign Insurer’s Subpart F Income, IRS Says http://www.uslawwatch.com/2010/04/19/tax/provisional-indemnification-receivables-includable-foreign-insurers-subpart-income-irs/ http://www.uslawwatch.com/2010/04/19/tax/provisional-indemnification-receivables-includable-foreign-insurers-subpart-income-irs/#comments Mon, 19 Apr 2010 14:06:09 +0000 admin http://www.uslawwatch.com/?p=1677

The Internal Revenue Service national office in Technical Advice Memorandum 201015030, released April 16, said provisional indemnification receivables (PIRs) for incurred but not reported loss reserves are includable in the calculation of Subpart F insurance income of a foreign insurer and its earnings and…

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]]> http://www.uslawwatch.com/2010/04/19/tax/provisional-indemnification-receivables-includable-foreign-insurers-subpart-income-irs/feed/ 0 Administration’s International Tax Proposals Stand-Alone Provisions, Not Package, Treasury International Tax Counsel Says http://www.uslawwatch.com/2010/03/24/tax/administrations-international-tax-proposals-standalone-provisions-package-treasury-international-tax-counsel/ http://www.uslawwatch.com/2010/03/24/tax/administrations-international-tax-proposals-standalone-provisions-package-treasury-international-tax-counsel/#comments Wed, 24 Mar 2010 10:00:28 +0000 admin http://www.uslawwatch.com/?p=1458

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 quick action, rather than as a package that is best dealt with in the context of fundamental reform, Treasury International Tax Counsel Manal Corwin said March 23.

“The administration is definitely looking at these as stand-alone provisions,” Corwin told the…

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]]> http://www.uslawwatch.com/2010/03/24/tax/administrations-international-tax-proposals-standalone-provisions-package-treasury-international-tax-counsel/feed/ 0 Senate Moves to Codify Economic Substance Doctrine in Passing One-Year Extension of Tax Breaks http://www.uslawwatch.com/2010/03/11/tax/senate-moves-codify-economic-substance-doctrine-passing-oneyear-extension-tax-breaks/ http://www.uslawwatch.com/2010/03/11/tax/senate-moves-codify-economic-substance-doctrine-passing-oneyear-extension-tax-breaks/#comments Thu, 11 Mar 2010 12:12:00 +0000 admin http://www.uslawwatch.com/?p=1254

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 imposing new penalties on firms using transactions structured for no purpose other than tax avoidance.
The American Workers, State, and Business Relief Act of 2010 (H.R. 4213) also would close a tax loophole that could allow paper manufacturers to claim a $1.01-per-gallon tax credit for their use of a pulp byproduct known as “black liquor” to power their plants…
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]]> http://www.uslawwatch.com/2010/03/11/tax/senate-moves-codify-economic-substance-doctrine-passing-oneyear-extension-tax-breaks/feed/ 0 Senate to Bring $31 Billion Tax Extenders Measure to Floor During Week of March 1 http://www.uslawwatch.com/2010/03/01/tax/senate-bring-31-billion-tax-extenders-measure-floor-week-march-1/ http://www.uslawwatch.com/2010/03/01/tax/senate-bring-31-billion-tax-extenders-measure-floor-week-march-1/#comments Mon, 01 Mar 2010 09:42:31 +0000 admin http://www.uslawwatch.com/?p=1068

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.

The Senate will begin with the bill…

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]]> http://www.uslawwatch.com/2010/03/01/tax/senate-bring-31-billion-tax-extenders-measure-floor-week-march-1/feed/ 0 Treasury Officials Defend Budget Proposal to Curb Abusive Transfer of Intangibles http://www.uslawwatch.com/2010/02/25/tax/treasury-officials-defend-budget-proposal-curb-abusive-transfer-intangibles/ http://www.uslawwatch.com/2010/02/25/tax/treasury-officials-defend-budget-proposal-curb-abusive-transfer-intangibles/#comments Thu, 25 Feb 2010 11:20:22 +0000 admin http://www.uslawwatch.com/?p=1042

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 it is based on substantial evidence of such shifting and is consistent with transfer pricing principles under tax code Section 482.

Both Treasury International Tax Counsel Manal Corwin and…

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]]> http://www.uslawwatch.com/2010/02/25/tax/treasury-officials-defend-budget-proposal-curb-abusive-transfer-intangibles/feed/ 0 Senate Majority Leader Reid’s Jobs Bill Gets Lackluster Reviews; Some Prefer Extending 2001, 2003 Tax Laws http://www.uslawwatch.com/2010/02/24/tax/senate-majority-leader-reids-jobs-bill-lackluster-reviews-prefer-extending-2001-2003-tax-laws/ http://www.uslawwatch.com/2010/02/24/tax/senate-majority-leader-reids-jobs-bill-lackluster-reviews-prefer-extending-2001-2003-tax-laws/#comments Wed, 24 Feb 2010 12:17:10 +0000 admin http://www.uslawwatch.com/?p=1027

Longer-term policies that give small businesses additional certainty about the tax climate in coming years may be better for the economy than the $16 billion in tax incentives set to pass the Senate Feb. 24, tax policy analysts told the Senate Finance Committee Feb. 23.
Senate Majority Leader Harry Reid’s (D-Nev.) measure, technically an amendment in…

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]]> http://www.uslawwatch.com/2010/02/24/tax/senate-majority-leader-reids-jobs-bill-lackluster-reviews-prefer-extending-2001-2003-tax-laws/feed/ 0