Circular 230 Disclaimer & Other Disclosures

To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or tax-related matter(s) addressed herein.

This blog is personal, reflects my own views and not the views of my employer, and has not be reviewed by my employer for completeness or accuracy.

Sunday, October 17, 2010

Taxation of Real Estate Investment Trusts: Real Estate Assets under IRC 856(c) - IRS Private Letter Ruling 201037005

Taxation of Real Estate Investment Trusts: Real Estate Assets under IRC 856(c) - IRS Private Letter Ruling 201037005

SubChapter M Tax: Draft law to implement UCITS IV Directive and amend tax rules presented from World Tax Advisor

SubChapter M Tax: Draft law to implement UCITS IV Directive and amend tax rules presented from World Tax Advisor

SubChapter M Tax: A Closer Look: The Dodd-Frank Wall Street Reform and Consumer Protection Act

SubChapter M Tax: A Closer Look: The Dodd-Frank Wall Street Reform and Consumer Protection Act

SubChapter M Tax: ICI - SEC and CFTC Seek Comment on Definitions Related to Regulation of Swaps

SubChapter M Tax: ICI - SEC and CFTC Seek Comment on Definitions Related to Regulation of Swaps

SubChapter M Tax: income earned from investments in the commodity-linked notes described in this letter will constitute qualifying income to Fund under section 851(b)(2)(A) - IRS Private Letter Ruling 201031007

SubChapter M Tax: income earned from investments in the commodity-linked notes described in this letter will constitute qualifying income to Fund under section 851(b)(2)(A) - IRS Private Letter Ruling 201031007

SubChapter M Tax: acts of indirect or direct self dealing by a RIC and disqualified persons - IRS private letter ruling 201031036

SubChapter M Tax: acts of indirect or direct self dealing by a RIC and disqualified persons - IRS private letter ruling 201031036

SubChapter M Tax: treatment of redemption proceeds of a tender offer of a fund as a dividend eligible for Dividends paid deduction - IRS private letter ruling 201032033

SubChapter M Tax: treatment of redemption proceeds of a tender offer of a fund as a dividend eligible for Dividends paid deduction - IRS private letter ruling 201032033

SubChapter M Tax: transfer of assets treated as a dividend - irs private letter ruling 201032035

SubChapter M Tax: transfer of assets treated as a dividend - irs private letter ruling 201032035

SubChapter M Tax: qualifying income from Commodity Linked Notes & Income from a CFC under 851(b)(2) - IRS Private Letter Ruling 201034011

SubChapter M Tax: qualifying income from Commodity Linked Notes & Income from a CFC under 851(b)(2) - IRS Private Letter Ruling 201034011

SubChapter M Tax: distributions of a non-publicly traded RIC stock and the dividends paid deduction - IRS Private Letter Rulings 201033010 - 201033013

SubChapter M Tax: distributions of a non-publicly traded RIC stock and the dividends paid deduction - IRS Private Letter Rulings 201033010 - 201033013

SubChapter M Tax: MSCPA InfoShare featuring Congressman Barney Frank

SubChapter M Tax: MSCPA InfoShare featuring Congressman Barney Frank

SubChapter M Tax: Investment Companies - AICPA Audit and Accounting Guide

SubChapter M Tax: Investment Companies - AICPA Audit and Accounting Guide

SubChapter M Tax: Request for Comments Regarding Implementation of Information Reporting and Withholding Under Chapter 4 - IRS Notice 2010-60

SubChapter M Tax: Request for Comments Regarding Implementation of Information Reporting and Withholding Under Chapter 4 - IRS Notice 2010-60

Tuesday, October 12, 2010

Implications of China’s foreign tax credit regime on outbound investment structures World Tax Advisor

World Tax Advisor


Implications of China’s foreign tax credit regime on outbound investment structures



China’s State Administration of Taxation (SAT) issued long-awaited guidance on 22 July 2010 (Bulletin No. 1 “Guidance on Administration of PRC Enterprise Foreign Tax Credit,” or “Guidance”) that provides a detailed interpretation and examples of the calculation of the foreign tax credit (FTC) available under articles 23 and 24 of the Enterprise Income Tax Law (EIT Law) and its implementation rules. The Guidance is intended to supplement Circular No. 125, a notice issued jointly by the SAT and the Ministry of Finance at the end of 2009.

ICI - President's Economic Recovery Advisory Board Report on Tax Reform Includes Mutual Fund and Retirement Recommendations

ICI - President's Economic Recovery Advisory Board Report on Tax Reform Includes Mutual Fund and Retirement Recommendations: "[24544]



September 16, 2010

TO: PENSION MEMBERS No. 37-10
TAX MEMBERS No. 28-10
FEDERAL LEGISLATION MEMBERS No. 6-10
RE: PRESIDENT'S ECONOMIC RECOVERY ADVISORY BOARD REPORT ON TAX REFORM INCLUDES MUTUAL FUND AND RETIREMENT RECOMMENDATIONS


The President’s Economic Recovery Advisory Board released its report on tax reform, proposing options for changes in the current tax system to achieve three broad goals: simplifying the tax system, improving taxpayer compliance with existing tax laws, and reforming the corporate tax system. [1]� The report includes one proposal relating to mutual fund taxation and a number of options to simplify savings and retirement incentives, described below.� The Board states that the report does not represent Obama Administration policy."
Paradysz Matera