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International Tax

International Tax 

This section contains comments and recommendations submitted by the AICPA on legislative, regulatory and administrative matters concerning international taxation and reporting of information.

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AICPA Comments on FBAR Form Changes

Article The AICPA submitted comments regarding FinCEN's proposed changes to the FBAR.
Published on May 06, 2013

AICPA Comments - International Tax Advocacy

Overview AICPA comments and recommendations regarding international taxation and reporting of information.  Keep up on the latest comments and advocacy developments.
Published on May 02, 2013

Written Statement Submitted to July 15, 2003 Congressional Hearing on International Competitiveness

Testimony Written statement submitted for July 15, 2003 Senate Finance Committee Hearing on International Competitiveness.  AICPA believes certain international provisions in the Internal Revenue Code are overly complex and disadvantageous to American businesses operating & competing abroad. Summarized are areas of international tax law in need of immediate attention.
Published on February 08, 2013

AICPA Comments on Foreign Tax Credit Proposed Regulations - December 18, 2007

Comment Letter AICPA recommends the IRS draft new language with respect to whether a payment is compulsory for an increase in a foreign subsidiary's foreign tax liability due to the sharing of losses or because of a combined settlement with a foreign taxing authority.
Published on February 08, 2013

AICPA Request for Confirmation of the Treatment of Persons with Signature or Other Authority Over, but No Financial Inte...

Comment Letter AICPA letter of 06.27.2011 requesting confirmation of the treatment of persons with signature or other authority over, but no financial interest in, a foreign bank or financial account for FBARs relating to pre-2010 calendar years.
Published on February 08, 2013

AICPA Comments on Notice 2005-74 Regarding the Effect of Certain Exchanges on Gain Recognition Agreements (GRAs) Under S...

Comment Letter AICPA recommends a successor US transferor in an asset reorganization be permitted to assume the obligations associated with an original GRA for the remaining term without triggering gain recognition. Other recommendations are also provided.
Published on February 08, 2013

AICPA Comments on CFC Look-Through Rule Guidance - December 11, 2006

Comment Letter AICPA requests the IRS and Treasury provide guidance on the CFC Look-Through Rule, specifically on the scope of payments covered by section 954(c)(6), and issues on dividends, earnings, and related party interest allocation, plus more.
Published on February 08, 2013

Request to Eliminate or Reduce Filing of FBAR for 2009 and Prior Years for Those with Signature Authority Over, but No F...

Comment Letter AICPA comment letter of 05.31.2011 on Foreign Bank and Financial Account reporting (FBAR) requesting to eliminate or reduce filing of FBAR for 2009 and prior years for those with signature authority over, but no financial interest in, a foreign bank or financial account.
Published on February 08, 2013

AICPA Comment Letter Examples as of March 27, 2007

Practice Aid Provided are examples to illustrate AICPA comments on the 2006 Department of the Treasury and the Internal Revenue Service issued Proposed Section 987 Regulations.
Published on February 08, 2013

AICPA Comments on 2006 Proposed Section 987 Regulations - March 29, 2007

Comment Letter AICPA recommends the Treasury and IRS reconsider the approach of the proposed regulations due to concerns that the regulations will frustrate the currency reforms made by The Tax Reform Act of 1986 and will pose an unreasonable compliance burden on taxpayers.
Published on February 08, 2013

AICPA Comments on Section 909 regarding Foreign Tax Credit Splitting Events by P.L. 111-226 - August 5, 2011

Comment Letter AICPA letter of 08.05.2011 on Section 909 regarding foreign tax credit (FTC) splitting events, enacted by P.L. 111-226.
Published on February 08, 2013

AICPA Comments on Proposed Foreign Base Company Sales Income Regulations Regarding Contract Manufacturing Arrangements -...

Comment Letter AICPA provides rationale for recommendations regarding proposed regulations providing guidance relating to foreign base company sales income, as defined in section 954(d).
Published on February 08, 2013

AICPA Additional Comments on Notice of Proposed Rulemaking (RIN-1506-AB08) regarding Amendment to the Bank Secrecy Act R...

Comment Letter AICPA Comment Letter of 11.19.2010 on foreign trust concerns associated with Foreign Bank Account Reporting (FBAR) in response to Notice of Proposed Rulemaking (RIN-1506-AB08) regarding Amendment to the Bank Secrecy Act Regulations.
Published on February 08, 2013

AICPA Comments on Notice of Proposed Rulemaking (RIN-1506-AB08) regarding Amendment - April 30, 2010

Comment Letter AICPA Comment Letter of 04.30.2010 on Foreign Bank Account Reporting (FBAR) in response to Notice of Proposed Rulemaking (RIN-1506-AB08) regarding Amendment to the Bank Secrecy Act Regulations.
Published on February 08, 2013

AICPA Proposed Regulations (REG-209006-89) Regarding Transfers Subject to Section 367(a) and Certain Cross-border Asset ...

Comment Letter AICPA Comment Letter of 05.20.2009 in response to Proposed Regulations (REG-209006-89) regarding transfers subject to Section 367(a) and certain cross-border asset reorganizations and nonrecognition distributions of the stock of certain foreign corporations by domestic corporations.
Published on February 08, 2013

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