The Tax Court held that a bank was not entitled to the tax benefits generated by a STARS transaction because the transaction lacked economic substance.
Credits
When Is a Foreign Tax Creditable Under Sec. 901?
The Supreme Court has granted certiorari in a Third Circuit case to resolve a circuit split and to answer the question of when a foreign tax is creditable under Sec. 901.
Guidance on Foreign Tax Credit Splitter Transactions
Treasury published temporary regulations to provide guidance on the Sec. 909 foreign tax credit splitter event provisions that were enacted in August 2010.
Foreign Limitations on Tax Loss Carryovers May Affect U.S. Foreign Tax Credits
Many foreign countries have recently made statutory changes to their tax loss carryover periods and limitations that may affect the U.S. accounting for income taxes of any U.S. company with foreign subsidiaries operating in jurisdictions where the limitations have been enacted.
Regs. on Foreign Tax Credit Splitter Arrangements
The IRS issued regulations on determining who has the legal liability to pay the foreign tax for foreign tax credit purposes and on the application of the “anti-splitter” rules of Sec. 909.
Foreign Tax Credit Regs. on Splitter Arrangements, Determining Who Is Liable for Foreign Tax
The IRS issued final regulations on determining who has the legal liability to pay the foreign tax for foreign tax credit purposes and temporary regulations on the application of the “anti-splitter” rules of Sec. 909.
Final Regs. Issued on Determining Amount of Tax Paid for Foreign Tax Credit Purposes
Final regulations have been issued that provide guidance on determining the amount of taxes paid for purposes of determining the foreign tax credit.
The Education, Jobs, and Medicaid Assistance Act of 2010
This item explains significant changes to foreign tax credits made by the Education, Jobs, and Medicaid Assistance Act of 2010.
Congress Votes to Limit Use of Foreign Tax Credits
P.L. 111-226 makes changes to how corporations can use the foreign tax credit and also terminates the advance refundability of the earned income credit (under Sec. 3507), effective for tax years beginning after December 31, 2010.
Congress Votes to Limit Use of Foreign Tax Credits – H.R. 1586
Congress enacted legislation that makes changes to the how corporations can use the foreign tax credit.
Foreign Tax Credits: Reducing Eight Categories to Two
The American Jobs Creation Act reduced the foreign tax credit limitation categories from eight to two: passive category income and general category income.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.