The US Treasury Department and the IRS last week issued guidance and a request for comment relating to a new information reporting provision with respect to taxable corporate acquisitions enacted as part of the American Jobs Creation Act of 2004.
Existing temporary regulations require corporations to report to both the IRS and their shareholders following a transaction in which there is an acquisition of control or a substantial change in capital structure and which may be taxable under the rules of Internal Revenue Code section 367(a).
These temporary regulations require information reporting with respect to corporate inversion transactions.
Proposed regulations would extend this information reporting to other corporate acquisitions and substantial changes in capital structure.
The authorities are seeking comments on their proposal by March 1, 2005, including whether dollar thresholds should be set for the reporting requirements.
A comprehensive report in our Intelligence Report series examining offshore and onshore corporate structures and their tax implications is available in the Lowtax Library at http://www.lowtaxlibrary.com/asp/subs_reports.asp and a description of the report can be seen at http://www.lowtaxlibrary.com/asp/description_report7.asp
Network Tweets
Network BlogsContent
provided by
|
Archive | Resources | Partners | Site Map | Links | Newsletter Archive | Contact | RSS Feeds | About | Syndication | Advertising & Marketing | Recruitment | Terms & Conditions | Privacy & Cookies
Copyright © 2012 - All Rights Reserved - Tax-News.com
IMPORTANT NOTICE: Tax-News.com has taken reasonable care in sourcing and presenting the information contained on this site, but accepts no responsibility for any financial or other loss or damage that may result from its use. In particular, users of the site are advised to take appropriate professional advice before committing themselves to involvement in offshore jurisdictions, offshore trusts or offshore investments.
Write a comment