U.S. taxation of international operations: trends and new developments

Article Abstract:

US taxation of international business operations is an expanding area of tax jurisdiction, based on legislation pending in 1995. A proposed tax on expatriating citizens, the IRS revenue procedure for determining whether limited liability companies will be treated as partnerships for tax purposes, the issue of US permanent establishments of foreign-controlled corporate groups as exemplified in a Japanese reinsurance case, the international tax simplification bill, proposed IRS passive income regs for banks and securities firms, and several proposed tax treaties are all examples of this trend.

International business enterprises, Multinational corporations, international

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Keeping current on currency: the new section 988 regulations

Article Abstract:

There are new IRS regulations governing foreign exchange transactions under IRC 988. These regulations cover agreements in nonfunctional currencies for debt between related persons, hedging of qualified payments such as executory contracts, debt instruments featuring contingent payments and optional alignment of accounting method with currency position reporting methods. These regulations represent an improvement over previous efforts.

Laws, regulations and rules, Foreign exchange

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A comparison of U.S. and U.K. tax regimes

Article Abstract:

The taxation of US investment income in the UK and UK investment income in the US are compared using sample US and UK companies. Issues discussed include choice of entity considerations, formalization of interests, inbound and outbound transfers of interest, joint ventures, subsidiaries, holding companies and the UK US tax treaty, all with an emphasis on tax planning.

United Kingdom, Foreign investments, Comparative analysis

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