Articles tagged: "international tax"

1: Implications of New Interest Expense Rules for US Multinationals

This article describes how the new Internal Revenue Code Section 864(e), which provides an opportunity for taxpayers to elect to modify their interest expense allocation for foreign tax credit purposes, will impact US multinationals.

2: New Interest Expense Allocation Rules

This article analyzes new Internal Revenue Code Section 864(e), which provides an opportunity for taxpayers to elect to modify their interest expense allocation for foreign tax credit purposes.

3: International Tax Free Reorganizations

In the world of international business, corporations that operate in different countries sometimes pursue reorganizations. They may do this to streamline operations to maintain a competitive advantage. They may also do it to change their corporate 'persona' with a new management and operating structure. When a multinational corporation reorganizes, it takes into consideration the tax implications.

4: Implications for Corporations

This article analyzes the implications for a U.S. corporation of provisions under Subpart F of the Internal Revenue Code.