Another Perspective on Taxation
The United States implements the Affordable Health Care Act, FACTA, and a 3.8% Medicare tax, while other jurisdictions tout their advantages for business, finance and investment. Clearly, the U.S. market is attractive in its own right which accounts for its take-it or leave-it attitude toward taxation incentives. Other jurisdictions, however, are not as fortunate and […]
CCA 201336018 / Collateral Consequences for Foreign Tax Purposes.
The payment of interest, other than in currency, between related corporations carries consequences for the calculation of the foreign tax credit (FTC). Chief Counsel Advice 201336018 (CCA) addresses such a situation in a U.S. consolidated group setting. The facts in the CCA are a U.S. parent corporation (P) owned all of the shares of two […]
U.S. Signs Six New Bilateral Agreements to Crack Down on Tax Evasion
The U.S. Department of Treasury made positive steps forward in December in its campaign against tax evasion, with the agency signingbilateral agreements with jurisdictions to comply with the tax law provisions outlined by the Foreign Account Tax Compliance Act. In a one-week time span in mid-December, Malta, the Netherlands, The Islands of Bermuda, and three UK […]
Tina Turner – No Longer Looking For a Job in the City
Tina Turner rose to fame, in part, on the song Proud Mary, whose lyrics begin with: “Lookin’ for a job in the city.” Recently, the Washington Post announced that Tina Turner relinquished her U.S. citizenship. Another publication stated that, for income tax purposes, there is a distinction between renouncing and relinquishing a person’s U.S. citizenship […]
