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International tax planning by US corporations has had a high profile in the media and in government over the past year, upstaging other important developments in US international taxation. In particular, announced plans for corporate expatriations, or "inversions" piqued congressional inte...

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Bibliographic Details
Published inInternational tax review p. 73
Main Authors Schmidt, Paul M, Bowers, Christopher P, Wallace, Kortney D
Format Magazine Article
LanguageEnglish
Published London Euromoney Institutional Investor PLC 01.01.2002
Subjects
Beneficiaries
Congressional committees
Controlled foreign corporations
Corporate income tax
Earnings
Federal court decisions
Foreign operations of US corporations
Foreign owned US companies
Foreign tax credits
Income shifting
Income taxes
International relations
Jurisdiction
Protocol
Related party transactions
Royalties
Tax court decisions
Tax credits
Tax incentives
Tax legislation
Tax rates
Tax reform
Tax treaties
Treasuries
Withholding taxes
United States > US
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Summary:International tax planning by US corporations has had a high profile in the media and in government over the past year, upstaging other important developments in US international taxation. In particular, announced plans for corporate expatriations, or "inversions" piqued congressional interest. Patriotic sentiments in the wake of the events of September 11 triggered a bi-partisan flood of proposed bills aimed at shutting down corporate expatriations and related cross-border transactions. While the anti-inversion proposals have loomed large, the past year also included the signing of protocols to treaties with the UK (proposed) and Australia (existing); the promulgation of regulations governing the use of partnerships under the subpart F regime, the use of domestic reverse hybrids, and the inclusion of stock options as expenses in cost-sharing agreements; and finally, the release of several judicial decisions dealing with economic substance, section 482, and other international topics. This article briefly describes the proposed anti-inversion legislation and highlights important new treaties, regulatory developments, and case law.
ISSN:0958-7594