Working with the new section 367 indirect transfer and GRA rules

Article Abstract:

The IRS issued final and temporary regulations providing guidance under IRC section 367(a) concerning treatment of outbound property transfers by US persons to foreign corporations in the context of corporate reorganization transactions defined in other code sections. The regulations include exceptions to the general section 367(a) gain recognition rule and indirect transfer rules.

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The source of income from personal services: not always a clear-cut determination

Article Abstract:

Proposed IRS regulations governing the taxation of personal services performed partly within and partly outside the United States are discussed. Topics include the reasons for the proposed changes, apportionment of fringe benefits, and the potential impact of the changes on individuals on assignment in foreign countries.

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Foreign partnerships: rules, issues, and planning opportunities regarding U.S. filing requirements

Article Abstract:

The authors discuss requirements under the Internal Revenue Code, as amended by the Tax Reform of 1997, that foreign partnerships file a partnership return of income if they have US source gross income or effectively connected income, regardless of whether the foreign partnership has any direct or indirect US partners.

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