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Channel: Uncategorized – Tax Sans Frontieres – an International Tax Law Blog
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SERVICES AND LOAN TRANSACTIONS MUST STAND ALONE FOR TRANSFER PRICING:INDIAN...

In a case involving an Indian company’s provision of an interest-free loan and software services to its wholly owned U.S. subsidiary the Delhi Income Tax Appellate Tribunal has held that the loan was...

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FATCA is Coming

On March 18, 2010, the Hiring Incentives to Restore Employment Act of 2010 was enacted into lawbrush wring a host of new information reporting requirements imposed on foreign financial institutions,...

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GE Pays No Taxes . . . Until It Does

Followers of the “GE Pays no Taxes” meme were handed a victory by the Second Circuit this week when the panel rejected an alleged abusive tax shelter in which a GE subsidiary purported to form a...

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Recent IRS Rulings

Just a couple recent IRS rulings involving Subpart F and PFIC elections. PLR 201201016  – Majority of proceeds from sale of Controlled Foreign Corporation’s banking assets not foreign personal holding...

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Recent Rulings – PLRs

PLR 201202001 Release Date: 1/13/2012 Payments to foreign bankruptcy creditors on non-subordinated notes are treated as payments on the notes, subject to Section 1446 withholding to the extent these...

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New 871(m) Regulations Issued on US-Sourced Dividend Equivalents

The Treasury Department just released temporary regulations for Section 871(m), governing nonresident aliens and foreign corporations holding notional principal contracts which provide for payments...

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PacBell Case Highlights International Gains & Unitary Income

PacBell’s recent victory in California illustrates how international matters can impact state-level taxation.  In Appeal of Pacific Bell Telephone Company and Affiliates (Case No. 521312), California...

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“PLAIN ENGLISH” TAKES UNLIKELY VICTORY AGAINST TAX CODE IN FOREIGN TAX CREDIT...

Some tax professionals are true artists. With poetic grace, they can demonstrate a client’s investment intent, business purpose, reasonable cause, or lack of willfulness. One thing they can’t do is...

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Planning on “pleading the Fifth”? Not when it comes to offshore banking

I have never actually heard someone take the Fifth.  Not as an advocate.  Not as opposing counsel.  Heck, not even as a juror. Three years of law school and nearly 15 years of practice and I’ve never...

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The Internal Revenue Code and the Infield Fly Rule

In honor of tomorrow’s opening day festivities, I give you my favorite Law Review article ever....

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