2005 Articles

IRS: Abusive USRPI Transactions: Dec-01-2005 — In its continuing quest to stop tax abuse, the IRS recently outlined two types of US real property transactions involving foreign (non-US) persons that the IRS views as abusive transactions designed to circumvent the US withholding tax.
Tax Alert: Katrina Emergency Tax Relief Act of 2005 (KETRA): Nov-04-2005 — As a result of this temporary provision, individual taxpayers can almost totally eliminate their federal taxable incomes for 2005.
US-Mexico: Transparencies: Nov-01-2005 — The United States and Mexico have agreed on when treaty benefits extend to a fiscally transparent entity formed under the laws of either country.
Cross-Border Income Securities: Oct-01-2005 — Income trusts have become popular with US companies that make Canadian public offerings. New variations may be more attractive to Canadian investors.
Cross-Border Estate Planning Basics: Jul-25-2005 — Canadian residents who acquire property located or deemed to be located in the United States are subject to potential U.S. estate tax on the value of that property owned at death.
IRS issues new regulations for partnership withholdings: Jul-14-2005 — This article by Hodgson Russ associate Marla Waiss was originally published in The Buffalo Law Journal, vol. 77, no. 56, July 14, 2005. Reprinted with permission.
US Partnership Withholding Regs: Jul-01-2005 — The IRS issued final and temporary regs regarding a US partnership’s obligation to withhold tax under Code section 1446 on effectively connected income allocable to a foreign partner.
Plot to Defraud the CRA: US Crime: Jun-01-2005 — The US Supreme Court upheld the conviction of participants in a scheme to defraud Canada of alcohol import taxes by smuggling liquor from the US into Canada, despite the common-law revenue rule that bars enforcement in US courts of foreign revenue laws.
Section 1441 Voluntary Compliance: Apr-01-2005 — Revenue procedure 2004-59 sets out procedures for a temporary voluntary compliance program for tax, withholding, and reporting obligations applicable to withholding agents in connection with payments to foreign persons.
Proposed rules permit tax-free cross-border mergers: Mar-24-2005 — The IRS recently issued proposed regulations allowing certain mergers and consolidations effective under foreign law to qualify as tax-free A reorganizations.
US Expatriates: Mar-02-2005 — The Jobs Creation Act of 2004, signed into law on October 22, 2004, substantially altered the expatriation tax rules (Code section 877) applicable to US citizens and long-term permanent residents who commit an expatriating act after June 3, 2004.
“A” Reorgs Embrace Forco: Mar-01-2005 — On January 5, 2005, the IRS issued proposed regulations that allow certain mergers and consolidations effected pursuant to foreign law to qualify as tax-free “A” reorganizations, if they meet certain criteria in the US law and qualify as reorganizations.

Web design and CMS by Algonquin Studios.