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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Treasury Tightens Rules on Transfers to Partnerships with Related Foreign Partners
Notice 2015-54, issued on August 6, 2015, describes regulations that the Treasury and IRS will issue under section 721(c), section 482 and section 6662 addressing certain transfers of property, in practice principally intellectual property, to partnerships with related foreign partners that the Treasury and the IRS view unfavorably. The regulations will complement and coordinate with tighter cost sharing regulations issued in 2011.
Corporate Tax Reform and Choice of Business Entity
A recent report by the Joint Committee on Taxation provides data on the entities through which business is conducted in the United States. The data are significant in the context of the debate over corporate tax reform, because they support the view that legislation aimed solely at corporate tax reform is unlikely to win wide political support from the U.S. business community.
IRS to Issue Guidance on Sale of Partnership Interests by Non-U.S. Persons
The IRS plans to issue guidance under section 864 relating to sales of certain partnership interests by non-U.S. persons. This guidance likely is intended to bolster the position taken by the IRS in Rev. Rul 91-32.