Assessing the newly-enacted foreign tax provisions

Article Abstract:

Legislation passed by the US Congress in 1996 regarding international tax matters was not wholly consistent with Clinton administration tax policy, but most provisions were accepted because they were attached to minimum wage and health insurance portability laws. The IRC section 956A excess passive assets rules for controlled foreign corporations were repealed, as were Puerto Rican and possessions tax credit laws. The Congress was able to pass laws taxing US source income earned by expatriates, though such laws may conflict with tax treaties. The administration supported changes in interest rates and other tax laws for foreign trusts.

Trusts and trustees, Trustees, Trusts (Law), Controlled foreign corporations, Expatriation, international

---

The need for a uniform software amortization regime

Article Abstract:

The regulations that the IRS is planning to issue under IRC section 197 should adopt a uniform amortization period of 36 months for all software so that the simplification that was the purpose of section 197 will actually be achieved. Section 197 contains ambiguities that leave the tax accounting treatment of customized software and custom-built software uncertain. Consistent tax treatment will not only promote compliance and reduce litigation but will also remove the distortions that currently favor off-the-shelf software.

Prepackaged software, Computer Software, Software Publishers, Software, Accounting and auditing, Intangible property, Intangible assets, Amortization

---

The unending lure of Puerto Rico's unique tax regime for the U.S. entrepreneur

Article Abstract:

American entrepreneurs can find substantial tax savings by residing and operating businesses in Puerto Rico, which has low corporate, capital gains, and income tax rates and exemptions. The choice of business form as either a Puerto Rican or US Section 936 corporation also has a dramatic effect on US corporate tax liability. Intercompany transfer pricing issues and the means of establishing bona fide residency are the other major considerations.

Foreign operations, Corporations, Puerto Rico, Foreign business enterprises, Domicile in taxation, Domicile (Taxation)

Similar abstracts:

• Abstracts: Consequences of preferred return provisions in a partnership agreement. The accountant's role in preparing and amending partnership or LLC agreements
• Abstracts: A note on the performance of foreign exchange forecasters in a portfolio framework. A note on an interest rate immunization strategy
• Abstracts: Market segmentation and the residual demand for tax-exempt bonds: empirical evidence from the elimination of interest deductions
• Abstracts: Business without boundaries: collaboration across organizations. Tools and dialogue set the stage for talent management at Johns Manville
• Abstracts: On the adequacy of legal documents: Factors that influence informed consent. Trust, control strategies and allocation of function in human-machine systems

This website is not affiliated with document authors or copyright owners. This page is provided for informational purposes only. Unintentional errors are possible.