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US Outbound Newsalert
The international tax services network provides access to recent tax news and advice on outbound structuring tax law.
May 2013
April 2013
- President’s FY 2014 budget renews prior international tax proposals but omits extensions for CFC look-through and active financing exception
- IRS rules that a contractual arrangement can create a tax entity
March 2013
February 2013
- Important revisions to Form 5471 filing instructions
- Recent Venezuelan devaluation could have big DASTM impact
- Senators introduce international tax bills with new and significant provisions
January 2013
- New proposed GRA regulations: Failures to file and deficiencies in GRAs and other documents
- Obama signs legislation retroactively extending CFC look-through and the active financing exception to subpart F
December 2012
November 2012
October 2012
August 2012
- Could the new Canadian legislative proposals affect your company?
- Federal Claims Court case on leased asset sale could benefit taxpayers
July 2012
June 2012
- Final regulations make minor changes to expired temporary regulations implementing ODL and OFL rules
- Joint Committee explanation of Obama's FY 2013 budget covers four new international tax provisions
- Fifth Circuit splits circuits by holding that the UK Windfall Tax is creditable
May 2012
April 2012
March 2012
- JCT provides revenue estimates for Obama’s FY 2013 international tax proposals
- IRS releases final and temporary regulations under sections 901, 909 and 704(b), addressing technical taxpayer rules and tax splitting events
- IRS applies same-country exception to CFC's sales, despite subsequent manufacturing elsewhere
February 2012
- Obama FY 2013 budget renews prior proposals with four additions; extends CFC look-through
- Senate Finance member Enzi introduces territorial tax bill with similarities and differences to Camp proposal
- Government reverses course: Issues Notice 2012-15 requiring GRAs for cross-border section 304 transfers
- Senator Enzi introduces a territorial tax bill
- IRS issues final technical taxpayer regulations
- IRS issues final and temporary foreign tax credit splitter regulations
January 2012
- Third circuit holds that UK windfall tax is not a creditable tax under section 901
- Temporary regulations under section 861 make a few targeted changes to the allocation and apportionment of interest
- IRS releases interest expense allocation and apportionment regulations
- Tax Court may address certain important Subpart F sales income issues for the first time
- PwC submits comments on Temp. Reg § 1.367(a)-9T(b) which address certain cross-border stock transactions
December 2011
- IRS issues final foreign base company sales income regulations
- IRS finalizes foreign base company sales income regulations
- IRS expects to release new foreign tax credit guidance before the holidays
November 2011
October 2011
September 2011
August 2011
July 2011
Contacts
- Doug McHoney
- International Tax Outbound Services co-leader
- Tel: +1 (513) 361 8165
- Michael Urse
- International Tax Outbound Services co-leader
- Tel: +1 (216) 875 3358
- Email ITS
