Determining the source of income in a changing world

Article Abstract:

Proponents of the application of residence-based sourcing rules to income resulting from international electronic commerce should consider the potential problems in instituting and administering such a system. Problems would be likely in areas such as digital property transactions, tangible property export sales, and electronic marketplace transactions. The 1996 US Treasury Dept publication entitled Selected Tax Policy Implications of Global Electronic Commerce opened the issue to a discussion which should continue before initiatives are adopted.

United States, Analysis, Electronic commerce, E-commerce, Domicile in taxation, Domicile (Taxation), international

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Planning under U.S. expense allocation rules

Article Abstract:

Interest and expense allocation rules for foreign income taxation can be mitigated with proper tax planning, either for transactions or business structures. Planning for interest rules includes using branches and partnerships instead of subsidiaries, deconsolidation, use of foreign subsidiaries for finance and dual character subsidiaries. Planning for expense rules includes intercompany lending, foreign subsidiary borrowing and use of foreign subsidiaries for finance.

Laws, regulations and rules, Foreign tax credit

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Beneficial uses of foreign entities and structures in tax planning for the U.S. multinational company

Article Abstract:

Multinational US companies can derive tax benefits from the use of foreign entities and business structures, for both US and foreign taxes. Areas to consider include non-transparent entities, transparent entities, US limits on foreign losses, tax transparency with non-transparent foreign entities, tax non-transparency with transparent foreign entities, later structural changes, the temporary rules and final rules for dual consolidated losses.

Foreign business enterprises

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