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Articles
1-91 out of 91 article(s)
| Title |
Author |
Type |
Date |
Words |
| Foreign Account Tax Compliance Act Of 2009 - Congress Sets Its Sights On Overseas Tax Evasion. |
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|
Nov 8, 2009 |
1323 |
| Expatriation and the new mark-to-market rules. |
Fava, Karl L. |
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Jul 1, 2009 |
5724 |
| Adopting or changing a foreign corporation's accounting method. |
Hui, Irene Pik-Wah |
|
Jul 1, 2009 |
1011 |
| U.S. tax effects of a foreign jurisdiction audit. |
Thompson, Bradley C.; Curran, Kevin M. |
|
Jul 1, 2009 |
646 |
| Darling's Review Of Offshore Regulation Is All Smoke And Mirrors. |
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Mar 4, 2009 |
774 |
| Automatic penalties for late forms 5471 and related forms. |
Sherr, Eileen Reichenberg |
|
Nov 1, 2008 |
409 |
| New Temp. Regs. under Sec. 905(c). |
Dash, Roopesh; Gupta, Sima; Landreneau, Frank |
|
Nov 1, 2008 |
2427 |
| Selected provisions of the Fifth Protocol to the U.S.-Canada Income Tax Treaty. |
Carsalade, Rafael |
|
Nov 1, 2008 |
1635 |
| MoFo Tax Talk, September 30, 2008. |
|
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Oct 7, 2008 |
5593 |
| IRS issues final "Killer B" regs. |
Nevius, Alistair M. |
|
Aug 1, 2008 |
353 |
| Adapting to the United Kingdom's new remittance basis rules. |
Whittall, Robert E. |
|
Aug 1, 2008 |
2407 |
| Foreign tax credits: reducing eight categories to two. |
Jones, Don |
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May 1, 2008 |
1236 |
| Risk, return, and objective economic substance. |
Luke, Charlene D. |
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Mar 22, 2008 |
20736 |
| Moving the "management and control" of a foreign corporation to achieve favorable U.S. tax results. |
Rubinger, Jeffrey L. |
|
Oct 1, 2007 |
5278 |
| IRS targets foreign tax credit generators. |
Pulliam, Darlene |
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Jun 1, 2007 |
249 |
| Compaq redux: implicit taxes and the question of pre-tax profit. |
Knoll, Michael S. |
|
Mar 22, 2007 |
15937 |
| Tax gap, legislative and regulatory initiatives focus of TEI's 57th Midyear Conference: new Ways & Means Chair, IRS Deputy Commissioner, and Treasury & OECD Officials Speak, FIN 48 commands attention. |
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Mar 1, 2007 |
1078 |
| Proposed "technical taxpayer" regulations shut down guardian and reverse hybrid structures. |
Rubinger, Jeffrey L. |
|
Feb 1, 2007 |
4374 |
| Sourcing the "unsourceable": the cost sharing regulations and the sourcing of affiliated intangible-related transactions. |
Benshalom, Ilan |
|
Jan 1, 2007 |
31044 |
| Limits on refunds for NOL carrybacks. |
Curran, Kevin |
|
Jul 1, 2006 |
932 |
| International provisions of TIPRA. |
Mattson, Andrew M. |
|
Jul 1, 2006 |
1246 |
| How reduced rates for capital gains and qualified dividends affect the FTC. |
Sigler, John N. |
|
Jul 1, 2006 |
4032 |
| Availability of the foreign earned income exclusion, FTCs and combat pay exclusion for U.S. government contractors. |
Ballard, Christine |
|
Apr 1, 2006 |
980 |
| Check-the-box: not always the right answer for certain foreign corporations. |
Patelski, Robert |
|
Apr 1, 2006 |
959 |
| Back-to-back computer licensing arrangements narrowly carved out of the ambit of sec. 901(1)(1). |
Calianno, Joseph M. |
|
Feb 1, 2006 |
2052 |
| Notice 2005-64 completes the IRS's Section 965 trilogy. |
Stoffregen, Philip A. |
|
Sep 1, 2005 |
9738 |
| Foreign tax strategies can be boon to multinationals: opportunities abound for multinational companies to take advantage of low-tax foreign jurisdictions to structure tax-advantaged programs. A number of countries provide major incentives to locate within their borders. |
Andreoli, Brian |
|
Sep 1, 2005 |
2048 |
| Marks & Spencer: EU claims for cross-border loss relief. |
Hare, Jonathan |
|
Jul 1, 2005 |
3184 |
| Forms of overseas operations. |
Shum, Michael G. |
|
Apr 1, 2005 |
5524 |
| New regulations curtail abuse of foreign tax credit by partnerships. |
Mannino, Laura Lee; Lai, Richard |
|
Mar 22, 2005 |
3272 |
| Forms of overseas operations: this two-part article explores the major characteristics, advantages and disadvantages of the different types of entities for conducting business overseas. |
Shum, Michael G. |
|
Mar 1, 2005 |
3983 |
| FTC baskets reduced to two. |
Zink, Bill |
|
Feb 1, 2005 |
800 |
| Interest expense allocation and apportionment options for FTC calculations. |
Zink, Bill |
|
Feb 1, 2005 |
766 |
| New repatriation dividend deduction. |
Gottschalk, Stefan |
|
Feb 1, 2005 |
1134 |
| Supercharged FTCs. |
Gottschalk, Stefan |
|
Feb 1, 2005 |
842 |
| American Jobs Creation Act of 2004 - Repatriation Provision. |
Libin, Jerome |
|
Jan 20, 2005 |
1415 |
| Bringing it home: summary and analysis of the repatriation provision of the American Jobs Creation Act. |
Satkoski, Elizabeth |
|
Jan 1, 2005 |
12770 |
| Allocating foreign taxes: IRS rules that partnerships must allocate foreign taxes in proportion to foreign income. |
Graham, Michael |
|
Sep 1, 2004 |
769 |
| Daily Tax Update: IRS Partially Withdraws Regs on Foreign Tax Credit Limitations; Issues Final Regs. |
|
|
Jul 20, 2004 |
818 |
| Daily Tax Update: Congress To Hold Abbreviated Work Week. |
|
|
Jun 9, 2004 |
666 |
| A guide to foreign corporation. |
Soltis, Sandra |
|
May 1, 2004 |
3656 |
| Daily Tax Update: Treasury and IRS Address Partnership Foreign Tax Credit "Splitter" Deals. |
|
|
Apr 21, 2004 |
827 |
| Potential opportunity to increase FTC use. |
Smith, Annette B. |
|
Jul 1, 2002 |
447 |
| Extraterritorial exclusion and the FTC. |
Packard, Pamela |
|
May 1, 2002 |
485 |
| The dual-consolidated-loss trap. |
O'Connell, Frank J., Jr. |
|
Sep 1, 2001 |
1648 |
| CFC buyer's sec. 338 election deprives seller of FTCs. |
Zarzar, Robert |
|
Jul 1, 2001 |
1410 |
| Effect of NOL carryovers on FTC. |
Crocco, Peter |
|
Jul 1, 2000 |
537 |
| Sec. 904 - base difference vs. timing difference for foreign taxes. |
Fischl, Alan |
|
Jul 1, 2000 |
784 |
| FTC denied in Compaq due to lack of business purpose. |
O'Connor, Peg |
|
Jan 1, 2000 |
858 |
| Affirmative use of entity structure in sourcing studies. |
Miller, Louis J. |
|
Sep 1, 1999 |
922 |
| Final loss allocation regs. result in increased FTC limitations. |
Kral, Mark E. |
|
Apr 1, 1999 |
938 |
| International implications of check-the-box regulations. |
Barrett, James H.; Ewing, William P. |
|
May 1, 1998 |
5079 |
| IRS targets multinationals. |
Sheard, Tony J. |
|
May 1, 1998 |
2466 |
| Simplification proposal could ease complexities of AMT for some businesses. |
Lyon, Andrew B. |
|
Jul 1, 1997 |
948 |
| FTC carryback eliminates interest on earlier underpayment of tax. |
Fuller, Thomas D. |
|
Nov 1, 1996 |
917 |
| Entering foreign markets - one step at a time. |
Benson, David M. |
|
Oct 1, 1996 |
2876 |
| Favorable court decision on FTC carrybacks may necessitate immediate action - refund potential. |
Everidge, Kathy |
|
Oct 1, 1996 |
704 |
| IRS issues proposed regulations on allocation and apportionment of research and experimental expenditures. |
Goodman, Mark E. |
|
Sep 1, 1996 |
1133 |
| MNCs should start addressing sec. 404A issues. |
Windsor, Josh G. |
|
Jul 1, 1996 |
831 |
| Financial accounting: EITF update. |
Volkert, Linda A. |
|
May 1, 1996 |
829 |
| Canadian company formed by U.S. S corporation will be considered a partnership. |
Zink, Bill |
|
Feb 1, 1996 |
642 |
| TEI endorses H.R. 1690, the International Tax Simplification and Reform Act of 1995. |
|
|
Sep 1, 1995 |
3029 |
| Determining foreign income tax credit. |
Weiss, Jeffrey |
Brief Article |
Aug 1, 1995 |
301 |
| Planning around the CFC netting rule. |
Bond, Dale |
|
Jul 1, 1995 |
930 |
| U.K. taxation: a quiet revolution. |
Dent, Christopher H. |
|
Jul 1, 1995 |
1205 |
| Proposed section 902 regulations. |
|
|
Jul 1, 1995 |
4164 |
| Implementation issues for the Mexican nonresident income tax. |
Romine, Marshall |
|
Apr 1, 1995 |
1277 |
| Sec. 304: IRS reconsiders "foreign subsidiary stock transfer" rulings. |
Andrews, Jim |
|
Jul 1, 1994 |
788 |
| Response of Canadian Department of Finance to questions posed at TEI liaison meeting on income tax issues. |
|
|
Jul 1, 1994 |
2029 |
| The latest round on FTCs and net loans. |
Alexander, John |
|
Jun 1, 1994 |
1327 |
| Unraveling the mysteries of Sec. 304 in international tax planning. |
Jacobsohn, R. Bruce |
|
Mar 1, 1994 |
5551 |
| Rulings clarify income sourcing regulations. |
|
|
Oct 1, 1993 |
518 |
| Miscellaneous international legislative proposals. |
|
|
Jul 1, 1993 |
951 |
| German stock dividends result in German tax refunds. |
Pugh, Erich |
|
Jul 1, 1993 |
846 |
| New U.S.-Netherlands treaty may adversely affect Netherlands holding company structures. |
Serota, Jack N. |
|
Jul 1, 1993 |
1435 |
| Investing in Eastern Europe through hybrid entities can ease U.S. FTC problems. |
Eigenbrode, Richard |
|
Jul 1, 1993 |
2056 |
| Clinton's tax plan: royalty and R&E provisions for multinationals. |
|
|
May 1, 1993 |
493 |
| FTC denied if competent authority not used in transfer pricing cases. |
Reavey, Edwin |
|
Apr 1, 1993 |
1675 |
| U.S.-Dutch agreement impedes treaty shopping. |
|
|
Mar 1, 1993 |
451 |
| Competent authority and FTCs. |
Berk, Nancy L. |
|
Feb 1, 1993 |
974 |
| U.S. Model Income Tax Treaty. |
|
|
Jan 1, 1993 |
4727 |
| U.S.-Russia treaty. |
|
Brief Article |
Oct 1, 1992 |
439 |
| Final regulations: CFC netting rule. |
|
Brief Article |
Jul 1, 1992 |
421 |
| FTC for individuals: treatment of 3% phaseout of itemized deductions. |
Dagg, Trevor |
Brief Article |
Jul 1, 1992 |
400 |
| S corporations: planning for FTCs. |
Beaumont, Simon J. |
|
Jul 1, 1992 |
1188 |
| Allocating charitable contributions in computing FTC. |
Fox, Stephen C. |
Brief Article |
May 1, 1992 |
418 |
| U.S. taxation of U.K. dividends. |
Hornsby, Brian |
Brief Article |
Apr 1, 1992 |
375 |
| Tax effects of the repeal of sanctions against South Africa. |
Watson, F. Douglas |
|
Nov 1, 1991 |
223 |
| Translation date for indirect foreign income taxes. |
Bernard, Michael J. |
|
Sep 1, 1990 |
586 |
| Comments on miscellaneous revenue issues considered at February 21-22, 1990, hearings, March 9, 1990. |
Burk, William M. |
|
Mar 1, 1990 |
2425 |
| Supreme Court holds for service in Goodyear case. |
Willens, Robert |
|
Feb 1, 1990 |
157 |
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