Final regulations on "dollar approximate separate transaction method" of accounting for hyperinflationary currencies

Article Abstract:

Final regulations under IRC section 985 establish that qualified business units of US taxpayers operating in nations with hyperinflationary economies must use the dollar approximate separate transaction method of accounting (DASTM). The DASTM regulations will require the qualified business units of a controlled foreign corporation will have to use the functional currency of the controlled foreign corporation. Currency is hyperinflationary if the compound rate over the prior 36 months exceeds 100%. Taxpayers can elect to use the method for open tax years beginning in 1987.

Tax accounting, Inflation accounting

---

IRS Notice 94-90 - notification requirements for multinationals making retroactive section 197 amortization elections

Article Abstract:

Notification statements must be sent to all commonly controlled corporations beginning in 1994 when a US taxpayer with controlled foreign corporations (CFC) elects IRC section 197 amortization of intangibles. Notification is required because all other entities under the control of the taxpayer will be bound by the election. Foreign corporations and CFCs that file returns in the US may retroactively elect section 197 treatment.

Accounting and auditing, Tax elections, Amortization

---

Impact of Notice 98-35 on hybrid arrangements under Subpart F; final section 367 regulations on outbound transfers of foreign stock and securities

Article Abstract:

Controversy over the IRS's position regarding hybrid branch transactions in relation to IRC Subpart F in Notice 98-35 resulted in its withdrawal. IRS final regulations under IRC section 367 regarding treatment of US persons' transfers of securities to foreign corporations were issued Jun 18, 1998. Those regulations are generally consistent with the proposed regulations which they replace.

Tax Law, Public Finance Activities, United States, Securities, Hybrid instruments (Finance), Hybrid instruments (Securities), Securities taxes, Branches (Business enterprises), international

Similar abstracts:

• Abstracts: Final regulations under section 382 clarify taxation of options. Proposed regulations narrow consistency rules on stock and asset acquisitions.
• Abstracts: Labor relations in the Dept. of Homeland Security: competing perspectives and future possibilities. Bargaining over the terms and conditions for striker replacements: is the NLRB about to change the rules?
• Abstracts: US tax scene. Final Regulations issued on attributing E&P to stock of a foreign corporation
• Abstracts: Rapprochement between the EU and the UN: history and balance of intersecting political cultures. Normative power Europe and the problem of legitimacy deficit: an Israeli perspective
• Abstracts: Temporary SRLY regulations make improvements, provide opportunities, and create issues. Section 446: a trap for the unwary in the treatment of transactions between members of a consolidated group

This website is not affiliated with document authors or copyright owners. This page is provided for informational purposes only. Unintentional errors are possible.