In advance of a September 8 Senate Finance Committee hearing, the Joint Committee on Taxation released a report summarizing U.S. tax treatment of cross-border income and related tax issues. The report includes a 25-page summary of existing tax rules applicable to inbound and outbound investment and a discussion of key issues such as the perceived need… Continue Reading
Category Archives: Corporations: International
Subscribe to Corporations: International RSS FeedIRS-Treasury 2011-2012 Business Plan Released
Posted in Corporate, Corporations: International, Estate and Gift, General, Partnership/LLCThe IRS released its annual Priority Guidance Plan on September 2, containing 317 projects that are priorities for the twelve-month period from July 2011 through June 2012. Although the total number of items on the list is similar to the prior year, some categories contain a more robust list of projects. For example, partnership tax… Continue Reading
Final “Killer B” Regulations – Triangular Reorganizations With Foreign Corporations
Posted in Corporations: InternationalThe IRS finalized the 2008 proposed and temporary “Killer B” regulations involving triangular reorganizations with foreign subsidiary corporations. The regulations address what may be viewed as repatriation transactions that are in the form of a reorganization. Generally speaking, the regulations treat the acquisition of Parent stock by the foreign subsidiary as a dividend occurring immediately… Continue Reading
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