Subpart F.: new foreign currency hedging exception
Article Abstract:
The final IRS regulations governing the tax treatment of foreign currency hedging transactions entered into by Subpart F taxpayers have expanded the definitions used to allow more transactions to qualify. Compared to the temporary regulations, more transactions are considered to have been entered into for the purpose of hedging under the final regulations, meaning that more transactions are excluded from foreign personal holding company income treatment. The temporary regulations also imposed strict reporting requirements that have been relaxed in the final regulations.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1996
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From storefronts to servers to service providers: stretching the peramanent establishment definition to accommodate new business models
Article Abstract:
Many countries are re-interpreting permanent establishment clauses in tax treaties in response to multinationals' practice of shifting income away from countries where they manufacture and sell products to jurisdictions with lower tax rates. This problem is especially evident in electronic commerce, but is present in other areas as well. The definition of "permanent establishment" in the OECD Model Treaty should be refined to solve the income-shifting problem and to establish more uniformity in taxation of multinationals.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 2003
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