The IRS targets perceived international tax abuses
Article Abstract:
The IRS and Clinton Administration in 1998 have taken measures to limit the possibilities of abusive international transactions. The measures are too broad and likely to stifle legitimate transactions and increase transaction costs. IRS Notices 98-5 and 98-11 state that the IRS will issue regulations limiting foreign tax credits in certain situations. The US Dept of Treasury's Feb 2, 1998 General Explanation of the Administrations's Revenue Proposals contains ominous requests for Congress to expand IRS regulatory power in this area.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1998
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Fiscally transparent Subpart F
Article Abstract:
IRS regulations issued on Mar 23, 1998 are directed at limiting the possibilities for abuses by corporations using hybrid branch entity structures. The final, temporary, and proposed regulations, which were issued in accordance with IRC Notice 98-11, treat such branches as separate entities and apply IRC Subpart F. The regulations also limit contract manufacturing business structuring. Negative congressional response may result in changes to the regulations.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1998
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Future directions of U.S. international tax policy
Article Abstract:
Tax policy for international activities of US companies should be reformed, specifically for outward bound activities of multinationals. Three structural areas which need consideration include deferral, foreign tax credits and sourcing or expense allocations. Goals for reform should include simplification, promotion of competitiveness, combining economic with legal analysis and the function of sourcing or allocation rules.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1992
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