Treasury, IRS target international issues

Article Abstract:

The set of anti-abuse regulations adopted by the Internal Revenue Service and the Treasury department was not only instrumental in establishing the lucidity of the technical rules provided by Subchapter K, but was also effectual in expanding the two agencies' concern for international issues. Several topics that these anti-abuse regulations address include foreign tax credit, lease stripping, shareholder requirements, revenue ruling and partnership transactions. The IRS also enacted the check-the-box Final Regulations in order to classify business organizations for federal income tax purposes.

Tax Law, Partnerships, International business enterprises, Multinational corporations, Business enterprises, United States. Internal Revenue Service, Tax credits, United States. Department of the Treasury

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TRA '97 repeals excise tax under Section 1491, enacts broad set of new rules for foreign partnerships

Article Abstract:

The Taxpayer Relief Act of 1997 (TRA '97) cancels the excise tax of Section 1491 to foreign partnerships. TRA '97 differentiates foreign partnership from its domestic counterpart, although increasing the requirements and fines to both types. The act implements a new set of identification, reporting, and penalties intended to handle transfers to foreign partnerships. Partnerships are different from corporations and should be treated as such.

Excise Taxes, Taxation, Partnership, Excise tax

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• Abstracts: Tax Court's second decision in Brown Group illustrates usefulness of anti-abuse regulations. International Developments

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