Current U.S. International Tax Scene
Article Abstract:
Foreign Personal Holding Company (FPHC) rules have been elaborated by the Tax Court. Two tests apply for FPHC: gross income and stock ownership. The fifty per cent value in corporate outstanding stock belonging to five or more United States residents or citizens proved to be the pivotal issue. Accumulated profits in net operating loss terms have been charged with more basic sense in an effort to curtail double taxation problems. Computation methodology is the central focus of that tax credit directed to the factoring of trade accounts of foreign subsidiaries, which is now popular with multi-national firms. That issue revolves around the profit of the trade account buyer. Other issues receiving attention are the conversion of foreign currency where a United States tax loss is involved and the treatment of tax amnesty payments under Section 901 as noncompulsory. United States property investment provisions foreign tax credit carry back refunds and protocol for the treaty convention with France.
Publication Name: Tax Management International Journal
Subject: Law
ISSN: 0090-4600
Year: 1983
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Current U.S. International Tax Scene - Practitioner's Viewpoint
Article Abstract:
An explanation is offered regarding the probable impact of the new 1980 United States-Canada tax treaty. If it is ratified Canadian investors will try to dispose of United States permanent establishment status. Installment sales are recommended. A clarification of the following topic areas is presented: 1) H.R.4561 regarding source income, 2) Internal Revenue Service (IRS) respond to Internal Revenue Code (IRC) Section 1248 transactions, 3) proposed regulations of foreign-controlled corporations under Section 6038A, 4) exemptions under new backup withholding rules, 5) the IRS position on the ten per cent voting stock ownership requirements for gaining indirect foreign tax credits under IRS Sections 902 and 960, and 6) IRS interpretation of the year income was earned for IRC Section 901 cases. Two cases, McCain v. Commissioner and Collins v. Commissioner are discussed as examples because the Tax Court upheld the IRS denial of benefits to United States' citizens living in the Panama Canal Zone.
Publication Name: Tax Management International Journal
Subject: Law
ISSN: 0090-4600
Year: 1984
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Focus on the Canadian International Tax Scene - Current Developments
Article Abstract:
The following topics are discussed: prevention of surplus stripping, withholding tax problems, protection of the Canadian fisc, the Canadian-United States Convention, non-arms's length transactions, gifts of Canadian property, payments to nonresidents, Canadian taxation of the American Telephone and Telegraph (AT&T) breakup and treaty developments. The 1980 Canada-United States treaty is still unratified. If it is passed, United States residents would be exempt from Canadian capital gains tax on particular gifts of property. Canada is active in the treaty area negotiating with Germany, Sweden, Indonesia and the Republic of China.
Publication Name: Tax Management International Journal
Subject: Law
ISSN: 0090-4600
Year: 1984
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