International Tax Blog

Recent Publications

Below are several interesting authorities or publications related to international tax that have been released recently. The U.S. Senate Permanent Subcommittee on Investigations (PSI), held a hearing on July 30, 2015 exploring the impact of the U.S. corporate tax code on foreign acquisitions of U.S. businesses and the ability of U.S. businesses to expand by acquisition. The associated report, "Impact of the U.S. Tax Code on the Market for Corporate Control and Jobs," details transactions... Read more →

Charts of Examples in Notice 2014-52

UPDATE - 11/1/16: Notice 2014-52 was made obsolete by T.D. 9761. See our blog post Over 50 New Situational Charts – Code §7874 Regulation Examples. On September 22, 2014, the IRS released Notice 2014-52. The notice announced that regulations will be issued under Code §§304(b)(5)(B), 367, 956(e), 7701(l), and 7874 to target corporate inversions. In summary, the notice aims to: Prevent inverted companies from accessing a foreign subsidiary’s earnings while deferring U.S. tax through the... Read more →

Charts of Examples in Notice 2014-44

Last week the IRS released Notice 2014-44, announcing that regulations will be issued under Code §901(m). Code §901(m)(1) provides that, in the case of a covered asset acquisition ("CAA"), the disqualified portion of any foreign income tax determined with respect to the income or gain attributable to relevant foreign assets ("RFAs") will not be taken into account in determining the foreign tax credit allowed under Code §901(a), and in the case of foreign income tax... Read more →

Treasury Issues Regulations to Close Repatriation Loophole

The U.S. Treasury Department recently issued temporary and proposed regulations under Code § 367(b) to close a loophole used by multinationals to repatriate cash from their foreign subsidiaries to the U.S. without paying tax on the repatriated earnings. Background On September 22, 2006, the IRS and Treasury Department issued Notice 2006- 85 (charted here), which announced that regulations would be issued under Code § 367(b) to address certain triangular reorganizations under section 368(a) involving one... Read more →