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Foreign corportations

Court clarifies definition of term used in foreign document request rules

Court clarifies definition of term used in foreign document request rules

LaRue, (DC OR 4/13/2016) 117 AFTR 2d ¶ 2016-624 A district court has concluded that the term “foreign-based documents,” which is used in the rules that govern IRS’s ability to obtain documents under the foreign document request rules, means documents held outside the U.S. and copies of those documents that are held in the U.S. […]

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Relative value of risk weighted assets might be used in apportioning supportive expenses

Relative value of risk weighted assets might be used in apportioning supportive expenses

Chief Counsel Advice 201614031 In Chief Counsel Advice (CCA), IRS has concluded that, at least theoretically, it was possible that a taxpayer could use the relative value of risk weighted assets as a reasonable key for apportioning deductions for overhead, general, and administrative expenses (i.e., “supportive expenses”) under Reg. § 1.861-8 to determine expenses effectively […]

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IRS issues final regs eliminating & modifying exceptions to coordination rule

IRS issues final regs eliminating & modifying exceptions to coordination rule

Reg. § 1.367(a)-3; Reg. § 1.367(a)-6; Reg. § 1.367(a)-6T; Reg. § 1.1248(f)-3 ; Reg. § 1.6038B-1 TD 9760, Indirect Stock Transfers and the Coordination Rule Exceptions; Transfers of Stock or Securities in Outbound Asset Reorganizations (Mar. 18, 2016). IRS has issued final regs, generally adopting temporary regs issued in 2013, that eliminate an exception to […]

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New guidance sheds light on arm’s length standard for interest on inbound intercompany loans

New guidance sheds light on arm’s length standard for interest on inbound intercompany loans

LB&I International Practice Service Transaction Unit, “Intercompany Interest Rates under the Situs Rule of IRC Section 482.” In a new International Practice Unit (IPU), IRS provides guidance to its examiners on whether the interest rate on a loan or advance from a foreign parent corporation (FPC) to a U.S. subsidiary (USS) (i.e., an inbound intercompany […]

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Private Letter Ruling – foreign parent didn’t have to waive treaty rights on domestic subsidiary’s liquidation

Private Letter Ruling – foreign parent didn’t have to waive treaty rights on domestic subsidiary’s liquidation

PLR 201606006 IRS has privately ruled that a foreign subsidiary will not be required to irrevocably waive its right to claim any applicable treaty benefits with regard to the Code Sec. 884(a) branch profits tax or the Code Sec. 881(a) excess interest tax with respect to any property entitled to nonrecognition treatment under Reg. § […]

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U.S. court rejects AIG, Bank of NY Mellon tax credit appeals

U.S. court rejects AIG, Bank of NY Mellon tax credit appeals

NEW YORK (Reuters) – A U.S. appeals court on Wednesday rejected efforts by American International Group Inc and Bank of New York Mellon Corp to recoup hundreds of millions of dollars of foreign tax credits that the Internal Revenue Service did not allow. By a 3-0 vote, the 2nd U.S. Circuit Court of Appeals in New York […]

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Regs to be issued on U.S. person’s transfers of property to partnership with foreign partners

Regs to be issued on U.S. person’s transfers of property to partnership with foreign partners

Notice 2015-54, 2015-34 IRB In a Notice, IRS has announced that it intends to issue regs under Code Sec. 721(c) to ensure that, when a U.S. person transfers certain property to a partnership that has foreign partners related to the transferor, income or gain attributable to the property will be taken into account by the […]

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FIRPTA Amendments Proposed To Encourage Foreign Investment In U.S. Real Estate

FIRPTA Amendments Proposed To Encourage Foreign Investment In U.S. Real Estate

Two senior members of the U.S. House Ways & Means Committee, one Republican and one Democrat, have introduced amendments to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) that aim to encourage greater foreign investment in U.S. real estate. Background on FIRPTA. In December of ’80, Congress enacted FIRPTA. It greatly revised the […]

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Final Regs Drop “Timely Form 5472 Even Though Untimely Return” Rule

Final Regs Drop “Timely Form 5472 Even Though Untimely Return” Rule

T.D. 9707, 12/23/2014; Reg. § 1.6038A-1, Reg. § 1.6038A-2, Reg. § 1.6038A-4   IRS has issued final regs that drop the requirement that Form 5472, “Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business,” be timely filed even when the corresponding income tax return is […]

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IRS provides additional time for withholding foreign trusts & partnerships to renew agreements

IRS provides additional time for withholding foreign trusts & partnerships to renew agreements

Click here for “Renewal of Withholding Foreign Partnerships and Withholding Foreign Trusts,” from IRS’s website. On its website, IRS has provided transitional rules for Withholding Foreign Trusts (WTs) and Withholding Foreign Partnerships (WPs) to renew their existing WT and WP agreements, which expire on June 30, 2014. Since IRS has not yet published the revised […]

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IRS to revise final “Killer B” regs for triangular reorganizations involving foreign corporations

IRS to revise final “Killer B” regs for triangular reorganizations involving foreign corporations

In Notice 2014-32, 2014-20 IRB, IRS has issued a Notice outlining the ways that it intends to revise the Code Sec. 367(b) “Killer B” final regs that were released back in 2011. Among other things, the Notice eliminates the deemed contribution model under the existing regs, modifies the amount of income and gain taken into […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney