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 … Continue reading 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.  … Continue reading International Tax Changes Take Flight

Say That Again: A Summary of AJACTLA

By David Shakow If you haven’t memorized the 433 pages of the latest version of the American Jobs and Closing Tax Loopholes Act of 2010 (undoubtedly named to allow for the euphonious acronym, AJACTLA), you are denying yourself a unique treat.  (To get the true flavor, don’t forget the fifteen pages of amendments included with … Continue reading Say That Again: A Summary of AJACTLA