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Federal / International Tax
2004 Articles
- IRS on Qualified Dividends
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Dec-01-2004
— In October 2004, the IRS provided guidance on the extent to which amounts received on or included in income by US individual shareholders of foreign corporations may be treated as qualified dividend income.
- Data Sharing: IRS and CIS
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Nov-11-2004
— The US Government Accounting Office determined the extent to which the IRS and the CIS (within the Department of Homeland Security) share and verify data and the benefits and challenges, if any, of increased sharing.
- Cross-Border Personal Services Income
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Nov-05-2004
— Proposed new IRS rules determine the source of income from personal services performed partly within the United States, applicable for tax years beginning on or after the date on which the regs are finalized.
- Subpart F: Discretionary Allocations
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Oct-10-2004
— Recently proposed IRS regs tie the allocation of a CFC's earnings among multiple classes of stock for tax purposes to FMV differences between the classes if the actual allocation depends on an exercise of discretion by the board of directors.
- Canco's US Compliance Issues
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Oct-09-2004
— Recently implemented IRS rules have compliance ramifications for Canadian companies that do business in the United States.
- Multinational Task Force
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Sep-17-2004
— Canada, the United States, the United Kingdom, and Australia have established a multinational task force to combat abusive tax transactions.
- Retroactive QEF Elections
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Jun-07-2004
— Recent IRS rulings provide further guidance on retroactive qualified electing fund (QEF) elections for stock in passive foreign investment companies (PFICs).
- US Tax Opinions and Practices
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May-14-2004
— The US Treasury recently proposed changes to the regulations that govern practice before the IRS. The proposals hope to restore, promote, and maintain the public's confidence in the honesty and integrity of professionals who provide tax advice.
- IRS: Treaty Filings, ITINs
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May-02-2004
— IRS Notice 2004-1 recently announced that eligibility for individual taxpayer identification numbers (ITINs) has been tightened to help eliminate their non-tax use.
- Simplified RRSP Reporting
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Apr-17-2004
— A new reporting regime for US resident and citizen RRSP and RRIF holders applicable for tax years beginning after 2002 greatly reduces the IRS-estimated time for compliance, compared to the prior regime.
- US Reduced Dividend Rate
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Apr-02-2004
— The US Jobs and Growth Tax Relief Reconciliation Act reduced the US federal income tax rate on qualified dividend income received by individuals to 15 percent, effective for tax years beginning after 2002 and ending for tax years beginning after 2008.
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