Practical problems in applying the section 367 regulations to outbound transfers of a publicly traded domestic corporation's stock

Article Abstract:

IRS regulation 1.367(a)-(3)(c) contains detailed and specific rules which must be met to receive nonrecognition of gain treatment in transactions where foreign corporation securities are exchanged for shares of US corporations owned by US persons. Rules regarding control and ownership tests, an active business test, and cases where gain recognition agreements are required are included.

Taxation, International aspects, Corporate reorganizations, Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation)

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The United States-France Tax Treaty

Article Abstract:

The author outlines the changes in the third income tax treaty between the US and France. Topics include taxes covered, residency, pension funds and nonprofits, dual-resident entities, real property, business profits, dividends, royalties, and capital gains.

France

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Do Singapore's domestic tax laws constitute a tax treaty override?

Article Abstract:

The author examines the question of whether changes made in 1996 to Singapore's Income Tax Act to curb real estate speculation constitute a tax treaty overide in breach of the Vienna Convention.

Tax Administration, Singapore

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