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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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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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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...
View ArticleThe 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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