By Jonathan Prokup During a course that I taught about tax treaties at last week’s TEI Houston Tax School, one audience member asked whether the exchange-of-information provisions of U.S. tax treaties apply not only to the federal government but also to state and local governments. I had to confess that I did not know the … Continue reading Can Foreign Governments Obtain Taxpayer Information From State and Local Revenue Agencies?
By 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 … Continue reading Treasury Finalizes Conduit Financing Regulations Under Section 881
By David L. Bernard TaxBlawg’s Guest Commentator, David L. Bernard, is the former Vice President of Taxes for Kimberly-Clark Corporation, a past president of the Tax Executives Institute, and a periodic contributor to TaxBlawg. My last blog post suggested that the best defense against transfer pricing assessments is the adoption of a globally consistent transfer … Continue reading The Benefits Of Seeking Competent Authority Relief For Proposed Transfer Pricing Adjustments
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