Update on US taxation issues

Resource Information

The work Update on US taxation issues 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

Update on US taxation issues

Creator

• Hammer, V

Subject

• withholding tax
• CFC
• tax authorities
• mutual assistance
• financial instrument
• SME

Language

eng

Summary

This article discusses recent developments in US taxation. 1) Future regulations will classify certain domestic partnerships as foreign partnerships for purposes of determining inclusions of Subpart F/Section 956 Income. 2) Final Regulations on diversification rules for qualified defined contribution plans holding publicly traded employer securities. 3) Large and midsize business industry director's directive: examination of dividends received deduction on separate accounts of life insurance companies. 4) Guidance on withholding of US tax on substitute dividend payments received by foreign taxpayers that transfer US dividend-paying securities in certain transactions. 5) Tax Court: foreign currency call option Is not a foreign currency contract under Section 1256. 6) United States signs Protocol to OECD Multilateral Treaty on Mutual Administrative Assistance in Tax Matters. 7) Second Circuit affirms Tax Court: taxpayers' capital contributions to S Corporations are not income to the S Corporations; thus, loan bases are not increased or restored. 8) Proposed Regulations intended to clarify effect of issuer's financial condition on modification of debt instruments. 9) Final Regulations provide that Section 704(c) anti-abuse rule must take into account tax liabilities of partners and their owners. 10) Federal Circuit affirms application of economic substance doctrine and upholds penalty assessments with respect to tax shelter. 11) IRS guidance on new markets tax credit. 12) Discussion of Notice 2010-50: IRS provides long-awaited Section 382(l)(3)(C) guidance. 13) Regulations on net operating loss carry-backs for taxpayers filing consolidated returns. 14) FASB proposes changes to fair value measurements. 15) Tax treaty update: Senate Foreign Relations Committee reports on protocol to treaty with New Zealand and on income tax treaty with Malta. 16) Tax Court holds "90% stock-loan program" transaction was a sale, not a loan, for income tax purposes. 17) FASB to issue a Proposed Accounting Standards Update on investment properties. 18) Tax Court: prepaid variable forward and stock-lending transactions were completed sales

Citation source

In: Derivatives and financial instruments. - Amsterdam. - Vol. 12 (2010),

Geographic coverage

North America

Language note

English