Curiouser and Curiouser: The Sourcing of Guarantee Fees Rises Again

By Jonathan Prokup It seems that one of our favorite topics is back in the news: the sourcing of guarantee fees.  As reported in today’s Tax Notes, Robert Driscoll, withholding technical advisor for LMSB, was recently quoted as saying that guarantee fees might not be considered U.S.-source income if the guarantor is a qualified resident … More Curiouser and Curiouser: The Sourcing of Guarantee Fees Rises Again

International Tax Changes Take Flight

The House of Representatives passed, and the President signed into law, H.R. 1586, the “FAA Air Transportation Modernization and Safety Improvement Act,” which curiously became the chosen vehicle for Congress and the Administration to provide assistance to states with budget shortfalls while paying for that assistance with changes in a number of international tax provisions.  … More International Tax Changes Take Flight