The information presented is only of a general nature, intended simply as background material, omits many details and special rules and cannot be regarded as legal or tax advice.

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October 2005

United States and Sweden Sign New Income Tax Treaty Protocol. [8K]

November 2004

IRS Proposes Section 482 Regulations on Intangible Property and Services. [58K]

February 1999

Transfer Pricing for Intangible Property under Section 482. [52K]

January 1999

IRS Proposes Foreign Partnership Reporting Rules. A discussion of and links to proposed regulations and draft IRS Form 8865 and instructions. [29K]

IRS Propses Modification of Revenue Procedure 65-17. A discussion of and link to Announcement 99-1. [6K]

U.S. Withholding Tax Regulations Update. [11K]

January 1998

Government Reneges on Subpart F Application of "Check-the-Box". A description of and link to Notice 98-11. [12K]

Contract Manufacturing and Subpart F: IRS Revokes Revenue Ruling 75-7. A discussion of the contract manufacturing implications of revocation of Revenue Ruling 75-7 by Revenue Ruling 97-48, with links to the two rulings. [16K]

IRS Finally Releases Foreign Trust Reporting Form for 1996. Links to the recently released IRS Form 3520, and related instructions, for use for 1996 transfers. [3.6K]

U.S. Treasury Announces Entry into Force of Several Income Tax Treaties. Effective dates for several U.S. income tax treaties ratified in 1997. [3.4K]

August 1997

International Tax Changes in the Taxpayer Relief Act of 1997. A description of the Taxpayer Relief Act of 1997 provisions affection U.S. federal income taxation of international transactions. [55K]

July 1997

IRS Provides Guidance on 1996 Foreign Trust Changes. A report on the changes wrought in the U.S. taxation of foreign trusts and their U.S. grantors and beneficiaries by the Small Business Job Protection Act of 1996, with links to the legislation and committee reports and to implementing proposed regulations and IRS Notices and forms. [66K]

December 1996

U.S. Treasury Department's Office of Tax Policy: Selected Tax Policy Implications of Global Electronic Commerce. Includes links to the full text of this paper. [6K]

February 1996

Transfer Pricing Examinations. A detailed examination of U.S. Internal Revenue Service audit procedures, with particular emphasis on transfer pricing issues. [69K]

November 1995

Treaty Override, Taxation of Offshore Stock Gains. A report on the Conference Committee's rejection of the U.S. Senate's addition of controversial tax treaty override and taxation of 10-percent offshore shareholder provisions to the 1995 budget reconciliation bill, together with an excerpt from the Conference Committee report and the text of those Senate provisions. [37K]

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