AICPA Foreign Income & Taxpayers

Home · Online Publications · The Tax Adviser · Tax Adviser Index 1990-1999 · Broad Categories · Foreign Income & Taxpayers
Foreign Income & Taxpayers

Accruals to related foreign persons. 92:447.
Agent authorizations. 92:241.
Aliens becoming U.S. residents. 91:150.
Allocation of income. 91:195; 99:156.
Allocation of loss. 99:222.
Anti-conduit regulations. 95:142.
APA procedures. 98:377.
Attribution rules for interest-stripping. 95:340.
Branch profits tax. 94:747.
Brown Group. 96:132, 207; 98:374.
California information reporting. 92:285.
Canada
Canadians with U.S. vacation homes. 92:290.
estate tax issues. 96:407.
goods and services tax. 98:81.
RRSPs. 96:469.
taxation of Social Security benefits. 99:306.
tax equalization payments to foreign expatriates. 97:355.
tax treatment of U.S. LLC. 96:661.
transfer pricing. 98:13.
Unlimited Liability Company. 96:73.
U.S. branch income. 97:690.
CFC
borrowing from. 90:90.
Form 5471. 99:477.
investment in U.S. property. 94:25.
"phantom" taxable profits. 95:527.
redemption of stock. 98:381.
shareholders and estimated taxes. 93:437.
use of contract manufacturers by. 98:148.
Check-the-box consequences. 99:554, 568.
Competent authority and FTC. 93:92.
Conducting business in foreign markets. 96:628.
Contract manufacturing. 98:382.
Corporate "branch" rule. 91:364.
Cost-sharing regs. 96:265; 97:27.
Cross-border securities lending
substitute payments. 92:345; 98:149.
Cross-border stock options. 99:156.
Deemed-paid foreign tax credit. 90:340.
DISCs
IC-DISCs. 94:552.
netting interest income and expense. 94:85.
Dual resident companies
losses. 90:94.
Duty on royalty payments. 93:713.
Earnings stripping rules. 91:797; 92:41, 53; 94:111.
Eastern European investments. 93:443.
EC tax developments. 92:293.
Employees
on overseas assignment. 91:567.
relocating overseas. 93:207.
Entity structure and sourcing studies. 99:628.
Estimated tax
avoiding penalties. 93:381.
Euro conversions. 98:150, 204; 99:394.
European check-the-box planning. 97:79.
Exclusions. 93:770.
Expatriation. 98:746.
Exportation
alternative tax vehicles. 91:183, 247.
Foreign
base company sales income. 96:408.
branch losses. 94:423.
corporation
    as qualified resident. 99:768.
    doing business with the U.S. 90:37.
    extension for. 94:150, 353.
    stock transfer to. 96:141.
currency losses. 96:446.
deferred compensation plans. 96:411.
earned income and housing amounts
    election to exclude. 93:534.
exempt organizations
    filing. 94:354.
gifts to U.S. persons. 97:74.
grantor trusts. 96:325, 676; 97:137, 350, 576.
individuals, filing requirements. 98:150.
insurance excise taxes
    refunds. 96:139.
joint ventures. 98:82.
nongrantor trusts. 96:676; 97:137, 350, 576.
-owned corporations
    AET. 93:431.
    information records. 90:557; 91:653.
partnership compliance rules. 99:88.
partnership income
    distributive share. 94:672, 95:285.
    receipt by affiliated group member. 95:404.
partnership return filing. 97:415.
partnership withholding. 98:220.
reporting rules. 98:374.
sales corporation grouping regs. 98:376.
subsidiary
    source of loss on sale. 97:550.
    stock transfers. 94:431.
tax credit. 98:290.
    and net loans. 94:351.
    carrybacks. 96:639.
    competent authority. 93:92.
    earned income exclusion. 90:493.
tax Internet sites. 97:133.
tax rates (chart). 98:737.
transactions
    Information reporting. 92:286.
Trust Tax Compliance Act of 1995. 95:700.
FSC
benefits. 95:540.
foreign parent-FSC structure. 93:173.
IRA-owned. 99:629.
FTC
grouping rules. 98:748.
indirect. 91:436.
interest expense allocation rules. 91:446.
opportunities. 93:171.
redetermination regs. 98:670.
software as export property. 92:720.
Funding international operations. 97:276.
German
acquisitions. 98:448.
stock dividends. 93:433.
-U.S. treaty. 90:428.
Global expansion, tax and accounting aspects. 99:416.
GmbH update. 93:315.
"High tax" exception. 91:433.
Holding companies. 91:97.
Hybrid entity
legislation. 97:688.
planning. 99:568.
treatment under subpart F. 98:294, 378, 517; 99:630.
Individual Taxpayer Identification Number. 95:700; 96:397; 97:275.
Information reporting
family attribution rules. 92:813.
Insurers. 90:232.
Interest paid to related foreign person
deduction limitation. 91:332.
Interest stripping. 92:519.
Investments in U.S. property. 90:145.
IRA
contributions. 94:141.
distributions to treaty country resident. 99:306.
"J" visa holders. 96:343.
LIFO conformity exception. 90:576.
Liquid assets lost in investment companies under FIRPTA. 98:455.
Loans to CFCs. 95:408.
Marriage issues. 99:308.
Mexican nonresident income tax. 95:211.
Netherlands Antilles interest exemption. 93:314.
Natural resources, sales of. 97:4.
Noncitizen spouses
estate planning. 90:688.
Nonqualified stock options. 90:20.
Nonresident alien
estate taxation. 93:643.
filing requirements. 91:574.
GST tax rules. 96:661.
reporting and disclosure requirements. 93:311; 96:207.
Sec. 874(a) deductions. 96:656; 97:354.
tax withholding. 90:255.
Offshore financing. 98:750.
OID on debt retirement. 92:456.
Outbound transfers
penalty for failing to report. 97:294.
regs. 97:104.
reporting. 99:478.
reporting relief. 97:355.
Payroll taxes
expatriates and nonresident aliens. 93:306.
PFICs. 92:362; 93:308; 94:142; 98:377.
Permanent establishments. 96:28.
Phaseout of itemized deductions for FTC claimers. 92:451.
Portfolio interest. 98:747.
Possessions tax credit. 91:583.
Property transfers to foreign partnerships. 99:305.
PTI ordering rules. 97:208.
Qualified business unit. 90:191.
Qualified intermediary application process. 98:452.
R&E expenses. 96:533.
Resident aliens. 92:718.
Related foreign entities
deducting payments to. 92:288.
Resident status. 92:92.
Retirement planning
Canadian cross-border. 92:94.
Return deadlines. 91:308.
Scholarships and fellowships. 95:638.
Sec. 304. 94:168.
Sec. 367(a) final regs. 97:686; 98:751.
Sec. 482 adjustments
penalties. 91:93.
Sec. 936 election, late. 90:558.
Sec. 959 ordering rules. 95:337.
Sec. 962 election. 90:564.
Sec. 1441 issues. 98:454.
South Africa. 91:736.
Soviet joint ventures. 90:414.
Taxation of nonimmigrant students, teachers and trainees. 95:370.
Tax harmonization in Europe. 91:84.
Trade name licensing in foreign markets. 97:209.
Transfer pricing
audits. 94:545.
conforming adjustments. 99:394.
competent authority. 93:230.
conference. 96:657.
documentation. 95:536.
guidelines. 96:265.
information sharing. 94:684.
intercompany royalties. 96:604.
IRS adjustments (chart). 96:196.
maquiladoras. 95:30.
"most current data" requirement. 96:11.
penalties. 93:310; 94:417; 99:224.
studies. 96:267.
Travel expenses for foreign nationals on U.S. internships. 96:343.
Treasury bills
estate tax on. 93:363.
Treaty developments. 96:144; 97:218, 306; 97:336; 98:466; 99:498.
U.K.
dividends. 92:240.
LLCs
    U.S. classification. 94:286.
subsidiaries. 93:250.
taxation system. 95:411.
tax residence. 96:268.
transfer pricing. 98:14.
U.S. affiliates
loans from foreign companies. 91:243.
interest income. 90:694.
U.S. distributor subsidiaries
buying in foreign currencies. 93:233.
U.S. foreign nationals. 99:392.
U.S.-Mexico treaty
defining residence. 94:287.
U.S.-Netherlands treaty. 93:442.
U.S. resident partner. 94:82.
Withholding
foreign mortgages. 93:103.
foreign partners. 93:560.