The IRS - out of step with its trading partners

Article Abstract:

The IRS's single-entity approach does not recognize and tax interbranch transactions, a practice placing it at odds with most of its trading partners in the Organization for Economic Cooperation and Development (OECD). Interbranch transactions, which take place between branches of the same entity, are recognized by the separate entity approach used by many OECD partners. The IRS's approach, which could lead to double taxation of certain transactions, is becoming outdated in an era of expanded global trade.

Multinational Corporations, United States, Practice, Organization for Economic Cooperation and Development, Transfer pricing, international

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IRS's evolving objectives culminate in proposed section 367 regulations

Article Abstract:

The IRS has revised IRC sections 367(a) and 367(b), which cover inbound and outbound transfers of assets to and from US tax jurisdiction. These changes became effective on Aug 23, 1992. However, despite IRS attempts to simplify these regulations, some transactions were made more difficult for taxpayers. These include the application of both sub-sections to a transaction, the change in definition of indirect inbound transfer and the recognition of gain on inbound transactions in foreign currency.

Laws, regulations and rules, Capital movements

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