US update

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The item US update represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
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Summary: This is the third in a regular series of articles that examines recent significant developments regarding US tax matters as these relate to international taxation, including OECD Report on Hybrid Mismatch Arrangements and Aggressive Tax Planning; the Division of Corporation Finance of the US Securities and Exchange Commission (SEC) issues disclosure guidance on exposure to European sovereign debt; IRS reminder of FATCA compliance requirements for foreign financial institutions and/or qualified intermediaries; Final Regulations on interaction between check-the-box regulations and multiple-party financing arrangements; Temporary Regulations on allocation and apportionment of interest expense; Temporary Regulations provide guidance on requirement that individuals report foreign financial assets to the IRS; IRS reopens offshore voluntary disclosure program: future guidance to be issued for residents of US possessions; IRS extends and expands transition relief for certain Puerto Rico group and/or retirement trusts; IRS Field Advice: providing financial statements using IFRS to taxpayer's lending bank violates LIFO conformity requirements; IRS identifies new locations as being in the "North American Area" for purposes of deducting convention and meeting expenses; foreign banks' interest in partnership secured lenders, not capital interests; legislative update: Permanent Investigations Subcommittee issues addendum to foreign earnings repatriation report

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Summary: This is the third in a regular series of articles that examines recent significant developments regarding US tax matters as these relate to international taxation, including OECD Report on Hybrid Mismatch Arrangements and Aggressive Tax Planning; the Division of Corporation Finance of the US Securities and Exchange Commission (SEC) issues disclosure guidance on exposure to European sovereign debt; IRS reminder of FATCA compliance requirements for foreign financial institutions and/or qualified intermediaries; Final Regulations on interaction between check-the-box regulations and multiple-party financing arrangements; Temporary Regulations on allocation and apportionment of interest expense; Temporary Regulations provide guidance on requirement that individuals report foreign financial assets to the IRS; IRS reopens offshore voluntary disclosure program: future guidance to be issued for residents of US possessions; IRS extends and expands transition relief for certain Puerto Rico group and/or retirement trusts; IRS Field Advice: providing financial statements using IFRS to taxpayer's lending bank violates LIFO conformity requirements; IRS identifies new locations as being in the "North American Area" for purposes of deducting convention and meeting expenses; foreign banks' interest in partnership secured lenders, not capital interests; legislative update: Permanent Investigations Subcommittee issues addendum to foreign earnings repatriation report