Heightened caution required to protect interest deductions of foreign-owned U.S. businesses

Lubin, Mark L.; Pollack, Lawrence A.
September 1994
CPA Journal;Sep94, Vol. 64 Issue 9, p88
Academic Journal
Discusses the need to exercise caution in applying financial methods to protect interest deductions of foreign-owned United States businesses. Significance of the Revenue Reconciliation Act of 1993; Changes in earnings stripping rules; Minimizing the impact of changes.


Related Articles

  • Treasury Revises FATCA Implementation Timeline.  // Venulex Legal Summaries;2013 Q3, p1 

    The article discusses the notice issued by the U.S. Internal Revenue Service (IRS) on July 12, 2013 which revised key dates relating to the implementation of the Foreign Account Tax Compliance Act (FATCA). The Notice postpones by six months several key FATCA start dates set forth in the final...

  • IRS Extends Implementation of Certain FATCA Provisions, Eliminates 2013 Reporting. Christensen III, Henry; Heller, Amy E.; Stone, J. Andrew P.; Gunther, Caitlin // Venulex Legal Summaries;2013 Q3, p1 

    The article reports on the U.S. Internal Revenue Service's (IRS) issuance of a notice that extends the implementation of certain provisions of the Foreign Account Tax Compliance Act (FATCA) by six months and eliminated reporting on U.S. accounts for 2013. Additional guidance is provided for...

  • IRS announces six-month delay in FATCA implementation. Granwell, Alan Winston; Jurewicz, Witold // Venulex Legal Summaries;2013 Q3, p1 

    The article reports on the U.S. Treasury Department and the Internal Revenue Service's announcement of a six-month extension to the start of the Foreign Account Tax Compliance Act (FATCA) withholding and account due diligence requirements to July 1, 2014. The delay was announced to give foreign...

  • Treasury general consents. Greene, Chris; Maddalena, Christina // Accountancy;Oct2000, Vol. 126 Issue 1286, p121 

    Reports on the amendment of the circumstances in which the British Treasury gives consent for certain transactions involving non-resident companies. Automatic consents given the Treasury; References in the Treasury general consents to an 'overseas group.'

  • Withholding for foreign partners. Basile, John; Morris, Edwin B. // CPA Journal;Apr95, Vol. 65 Issue 4, p52 

    Reports that withholding rules under Sec. 1446 are often overlooked by unwary accountants. Special rules for publicly traded partnerships; Requirements from businesses with foreign partners; Elaboration on the concept of `effectively connected taxable income.'

  • Erosion of Section 936 funds has minimal consequences. Valentin-Mari, Jeffry // Caribbean Business;8/24/2000, Vol. 28 Issue 33, p32 

    Discusses the impact of the elimination of federal tax incentives in Puerto Rico. Analysts' initial concern that the move would be disastrous for the island's financial system; Legislation by the United States Congress of provision exempting manufacturing companies from paying federal income...

  • Dems Say Farm Bill Will Pass.  // FoodService Director;8/15/2007, Vol. 20 Issue 8, p1 

    The article reports on the possible passage of a five-year farm bill according to U.S. Democrats. It states that this news represents a major victory for school foodservice operators, who have been fighting for financial support to sustain healthier food programs. Republicans who formerly...

  • When customer service trumps tax penalties. McLaughlin, Patrick // Connector Specifier;Mar/Apr2009, Vol. 25 Issue 2, p7 

    The author shares his thoughts on the plan of U.S. President Barack Obama to impose higher tax on U.S. companies doing business overseas. He cites the complexity involved in the effort to rein in U.S. manufacturers using overseas resources as part of their business plans. He suggests encouraging...

  • IRS opens online FATCA registration system: financial institutions may now sign in. Granwell, Alan Winston; Francese, Gerald A.; Jurewicz, Witold // Venulex Legal Summaries;2013 Q3, p1 

    The article announces the opening of the U.S. Internal Revenue Service's (IRS) Foreign Account Tax Compliance Act (FATCA) Registration Web site. The site allows financial institutions (FI) to electronically register themselves and their branches without the need to print, complete and mail paper...


Read the Article


Sorry, but this item is not currently available from your library.

Try another library?
Sign out of this library

Other Topics