US Inbound Newsalert

This publication provides news on tax and legislative issues related to companies headquartered outside the US doing business in the US.

July 2012

• Luxembourg-Poland protocol eliminates PE exemption, affecting US investments in Poland

June 2012

• Tax Court opinion upholds taxpayer's debt characterization of US intercompany debt
• New section 7874 regulations significantly narrow ability to claim substantial business activities in a foreign country

May 2012

• IRS provides guidance on repeal of portfolio interest exemption for bearer bonds and the expanded scope of registered obligation

April 2012

• FATCA implications for non-financial services corporations

March 2012

• OECD report on cross-border hybrid mismatch arrangements, UN publishes model double taxation convention

February 2012

• IRS releases guidance on section 163(j) excess interest expense limitation and section 871(m) dividend equivalent payment sourcing
• Obama Administration's FY 2013 Budget: Re-proposals and new international tax provisions

December 2011

• IRS issues final anti-conduit regulations on the treatment of disregarded entities

November 2011

• IRS releases proposed guidance addressing income of foreign governments under Section 892