The Resource US update

US update

US update
US update
This article examines recent significant developments regarding US tax and accounting as these relate to international taxation, including: mark-to-market valuation of securities; FBAR filing deadline for certain individuals with only signature authority over foreign financial accounts extended; treatment of certain triangular reorganizations involving foreign corporations; avoidance of income inclusion when a CFC acquires "United States property" in certain non-recognition transactions; certain information return filing requirements for interests in foreign financial assets and PFIC suspended; Financial Accounting Standard Board (FASB) to allow offsetting of derivatives; guidance for IRS examiners on codified economic substance doctrine and related penalties; "qualified foreign corporations": 15% individual income tax rate and application of treaty test; certain transfers or assignments of derivative contracts not "an exchange" for the non-assigning counterparty; certain swap contracts and similar arrangements excluded from treatment as "Section 1256 contracts" and definition of notional principal contract revised
Citation source
In: Bulletin for international taxation. - Amsterdam. - Vol. 65 (2011), no. 12 ; p. 674-683
Hammer, V
Geographic coverage
North America
Language note
  • valuation
  • foreign bank
  • reorganization
  • CFC
  • economic substance
  • notional principal contract
US update

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      52.3736660 4.9336932
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