Data reduction techniques in the allocation of operational expenses under I.R.C. section 861: a structured approach

Article Abstract:

The author discusses acceptable methods for apportioning expenses to foreign and domestic source income. A brief overview of data reduction techniques is included. Topics include activity-based costing and the key variables in a firm's internal and external environment.

International aspects, Tax accounting, Tax planning, Income accounting

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Preventing international arbitrage in reorganizations: an analysis of the gap closing provisions of the recently released final regulations to section 367(b)

Article Abstract:

The authors discuss IRS code section 367(b), which covers corporate reorganizations in which the status of a foreign corporation as a corporation is necessary for the application of nonrecognition provisions. Significant changes to the section since 1991 are covered.

Foreign corporations, Corporate reorganizations, Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation)

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Exempting transportation income under the proposed section 883 regulations

Article Abstract:

Proposed IRS rules to exempt certain U.S.-source transportation income of foreign corporations from federal income tax are discussed. The rules apply to ships and planes when the foreign nation grants an equivalent exemption to U.S. corporations.

Airlines, Shipping industry, Foreign source income taxation

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