The United States finally ends the Puerto Rico and possession credit of Code section 936 - a decade from now

Article Abstract:

The US possession tax credit will be phased out in 10 years, under a repeal included in the 1996 Small Business Jobs Protection Act. Under the credit, domestic corporations' income sourced from US possessions, particularly Puerto Rico, is exempted from taxation. The law was designed to promote economic development, but it also has discouraged Puerto Rican statehood. Multinationals' abuses led to the active business income restrictions imposed on the credit in 1993. The repeal's effect on qualified possession-source investment income, existing claimants, and income limitation cap calculation is analyzed.

Administration of General Economic Programs, Corporate Tax Deductions & Exemptions, Regulation of Multi-Nationals, Laws, regulations and rules, Corporate taxes, Multinational corporations, Puerto Rico, International trade regulation, Tax credits, Possessions tax credit

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The tax impact of changing to the Euro under U.S. tax law

Article Abstract:

US tax treatment of the single European currency conversion can be analyzed by reference to European Community actions and US tax law. IRS regulations sections 1.1001-3 and 1.985-5 provide some guidance regarding the conversion's being treated as a significant modification or change in functional currency. The tax treatment determination affects holders and issuers of financial instruments as well as currency holders.

Tax Law, International Affairs, European Community, Other General Government Support, Coinage & Currency, Analysis, Influence, Money, Euro (Currency), Tax policy, European Union

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