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August 29, 2003 - admin

IRS plans for international tax guidance this year

Every year, the IRS publishes a Priority Guidance Plan. It lists the subject matters in which they plan to publish tax regulations and other administrative guidance during the year.

This year shows an impressively ambitious group of topics in the international tax arena. Here is the list, as published by the IRS:

A. Subpart F/Deferral

# Regulations on the allocation of subpart F income.
# Regulations under section 959 on previously taxed earnings and profits.
# Guidance on the PFIC provisions.

B. Inbound Transactions

# Guidance on cross-border pension distributions.
# Guidance under section 1441.
# Guidance on securities lending.
# Guidance on the treatment of certain financial products for withholding purposes.
# Regulations under section 1446.
# Regulations relating to the reporting of bank deposit interest.

C. Outbound Transactions

# Guidance on international restructurings.
# Guidance follow-up to Notice 2003-46.

D. Foreign Tax Credits

# Regulations on the allocation of foreign taxes under section 901.
# Regulations under sections 902 and 904.
# Regulations on look-through treatment for 10/50 company dividends (see Notice 2003-5).
# Regulations on the change of taxable year and foreign tax credits.

E. Transfer Pricing

# Regulations on the treatment of cross-border services.
# Regulations on cost sharing under section 482.
# Guidance on the APA process (Rev. Proc. 96-53).
# Regulations on global dealing.

F. Sourcing and Expense Allocation

# Guidance on interest expense apportionment.
# Regulations on the allocation and apportionment of charitable contributions.
# Regulations relating to the treatment of fringe benefits.
# Guidance on the source of payments for cross-border use of property.
# Regulations under sections 863(d) and (e).

G. Treaties

# Treaty guidance on the determination of residence for dual resident companies.
# Treaty guidance under the independent services article for nonresident partners.
# Guidance on the procedures for claiming treaty waiver of insurance excise tax.
# Guidance on reporting for Canadian RRSPs and other plans.

H. Other

# Guidance on the definition of “qualified foreign corporation” for purposes of taxation of dividends received by individuals.
# Regulations under section 269B.
# Guidance on cross-border insurance issues.
# Guidance on possessions issues.
# Regulations concerning the treatment of currency gain or loss.
# Regulations under section 1503(d).

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