Mr. Cope monitors the development of U.S. tax law daily through postings on government websites, daily tax publications, monthly tax journals, tax newsletters, tax conferences and meetings of professionals organizations in New York and Washington. Each month he publishes the Tax Insights Blog, which describes and analyzes significant U.S. tax developments (e.g., judicial decisions, regulations, proposed tax legislation) having cross-border tax consequences. The blog's content should be of interest to U.S. businesses with foreign operations and businesses headquarted outside the United States with U.S. investments or U.S. operations.
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IRS Provides Statistics on Competent Authority Activity in 2013
On April 30, 2014, the Large Business and International Division of the IRS released statistics on activity in the Office of the United States Competent Authority (“USCA”) during 2013. In general, the statistics show the IRS’s increased resources devoted to the USCA have increased the number of cases resolved.
New U.S. Corporate Tax Return Data Offer Insights on Inbound Investment
On July 9 the IRS released a report reviewing and analyzing corporate tax return data for 2010 (the “Report”). This is the latest year for which the IRS has released such data. The Report is of interest because it offers insights into the reported activities of non-U.S. companies carrying on business in the United States. A non-U.S. (foreign) corporation that is engaged in a U.S. trade or business during the taxable year is required to file a Form 1120-F (U.S. Income Tax Return of a Foreign Corporation) for that year.