Recently released FSAs offer insights into IRS treatment of USRPIs

Article Abstract:

The IRS has released two field service memoranda (FSAs) which may be useful for the guidance they provide regarding US Real Property Interests (USRPIs). The FSAs concern the treatment of foreign investments in US real property. One FSA is helpful in its clarification of the meaning of 'going concern value' in IRS regulation 1.897-1(o)(2)(ii). The other is less helpful due to its questionable treatment of interest received on installment contracts as portfolio debt rather than trade or business debt.

Foreign investments, Real estate, Real property

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IRS issues temporary and proposed regulations regarding Euro conversion

Article Abstract:

The IRS temporary and proposed regulations concerning the Euro currency 1999 conversion, which were issued July 29, 1998, focus on two issues most important to U.S. taxpayers dealing in legacy currency. Realization of gain in transactions involving financial instruments and whether functional currency is changed by the conversion are the issues addressed. Application of the regulations will generally result in deferral or spreading of gains and losses and minimal tax administration costs.

European Union, Other General Government Support, Coinage & Currency, Interpretation and construction, Money, Euro (Currency)

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Proposed regulations define reporting requirements with respect to foreign partnerships

Article Abstract:

Tax reporting rules for many partners of foreign partnerships changed with the addition of IRC section 6031(e) by the Taxpayer Relief Act of 1997. Three sets of IRS proposed regulations have been issued under sections 6038, 6046A, and 6038B which provide relevant guidance. Problems may arise concerning repetitive reporting of some information, especially where controlled foreign corporations are holding companies.

Partnerships, Laws, regulations and rules, International aspects, Partnership, Information returns

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