By Jonathan Prokup and Dustin Covello Following the release of Ann and Mitt Romney’s tax returns, the news media and political commentators of all stripes have – to paraphrase Arlo Guthrie – detected, neglected, selected, rejected, and inspected those returns for a variety of commercial and political purposes. As expected, the return shows substantial income, [...]
Archive for the ‘International’ category
Silence Is Golden: Can Treasury Offer Guidance About The Tax Consequences Of A Euro Breakup?
January 23, 2012By Jonathan Prokup In this morning’s Tax Notes (subscription required), Jeremiah Coder addresses a topic that we at the Tax Blawg have discussed a couple of times over the past two years: the tax consequences of a potential breakup of the euro. For our prior coverage, see here and here. As the currency lurches towards [...]
Treasury Finalizes Conduit Financing Regulations Under Section 881
January 9, 2012By Jonathan Prokup On December 9th, the IRS issued final regulations under Code section 881 that treat a disregarded entity as a person to determine whether a “financing arrangement” exists for purposes of applying the conduit financing regulations. The finalized regulations may deny tax benefits otherwise available from U.S. tax treaties when a multi-party financing [...]
Tax Foundation: Rethinking U.S. Taxation of Overseas Operations
December 1, 2011By Jonathan Prokup Our in-house and private-practice corporate readers will likely enjoy one of the Tax Foundation’s newest reports: Rethinking U.S. Taxation of Overseas Operations. As the abstract describes: The United States produces a third of the world’s wealth but contains less than 5 percent of the world’s population. This disparity pushes many U.S. businesses [...]
Businesses Prepare For The End Of The Euro; Will Treasury Do The Same?
November 29, 2011By Jonathan Prokup According to the Financial Times, companies around the world are preparing for the possibility of a breakup of the euro. Given the currency devaluation that would likely occur in countries coming out of the euro, these companies are preparing for the impact that such an event would have on balance sheets (e.g., [...]
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Phil Karter
Jonathan Prokup
David Shakow
George Connelly, Jr.
Buck Buchanan
David Bernard
Dustin Covello
Heather Pesikoff
Hale Sheppard
