US update

Resource Information

The work US update represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

US update

Creator

• Hammer, V

Subject

• effectively connected income
• foreign bank
• foreign tax credit limitation
• CCCTB
• windfall profits tax
• withholding tax
• information obligation

Language

eng

Summary

This article, which is the first in a regular series, considers important recent developments regarding the United States and international taxation, including US companies and the EU proposal for a Common Consolidated Corporate Tax Base, revised guidance on implementation of information reporting and withholding under FATCA, Final Regulations on reduction of foreign tax credit limitation categories under section 904(d), guidance on closing cases involving both section 965 foreign earnings repatriation and transfer pricing adjustments, final US Treasury rule on Form TD F90-22.1 (filing requirements for reporting foreign financial accounts), two opinions issued by the US Tax Court on UK windfall tax of 1997 on utilities, changes to effectively connected income sourcing rules and new 4% excise tax om sales to related parties in Puerto Rico, 2010 tax relief approved for corporate and individual taxpayers in Puerto Rico, and IRS organizational changes

Citation source

In: Bulletin for international taxation. - Amsterdam. - Vol. 65 (2011), no. 6 ; p. 333-341

Geographic coverage

North America

Language note

English