United States

• Published in: International tax review p. 73
• Main Authors: Schmidt, Paul M, Bowers, Christopher P, Wallace, Kortney D
• Format: Magazine Article
• Language: English
• 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
• ISSN: 0958-7594

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.