Financing infrastructure investment by taxing foreign corporations
Pres Clinton's idea of raising the income tax on US-based subsidiaries of foreign corporations and earmarking the proceeds for infrastructure enhancements is unlikely to succeed. The administrative system currently in place for taxing such corporations is already cumbersome. Further, the notion of raising taxes disproportionately on foreign firms poses diplomatic problems. Indeed, the existing system of taxing foreign firms needs to be reformed.
Publication Name: Regulation
Contribution to capital or contribution to confusion?
The guidance provided by the IRS in Technical Advice Memorandum (TAM) 9822005 may have greater impact on ancillary issues than on the primary issue regarding cancellation of debt income. Application of common law, interaction between IRC subsections 108(e)(6) and (e)(10)(A), and related party transactions are dealt with deceptively. The TAM is of limited direct benefit, but should not be disregarded due to the treatment of ancillary issues.
Publication Name: Journal of Corporate Taxation
Cross-border tax issues of collective investment institutions and the Italian approach
Issues pertaining to taxation of collective investment institutions (CII) are discussed alongwith Italian domestic legislation to recognize these institutions.
Publication Name: Intertax
- Abstracts: Swapping bond investments to reduce capital gains - an illustration. Avoid being snared by unexpected depreciation recapture
- Abstracts: The fiduciary responsibilities of investment bankers in change-of-control transactions. Typography in the U.S. Reports and Supreme Court voting protocols
- Abstracts: Using local area unemployment statistics in federal program administration. Congress can disapprove federal agency rules
- Abstracts: Negotiating competition. The false security of continuation-in-part applications. Selling an operating business in bankruptcy
- Abstracts: Comparing apples to oranges: the need for a new media classification. The new audiovisual media services directive: television without frontiers, television without cultural diversity