Practical US/International Tax Strategies

Download PDF of November 30, 2008 Issue of Practical US/International Tax Strategies
23 Dec 2008

The Tax Effects of Restructuring a Foreign Subsidiary
By Joseph B. Darby III (Greenberg Traurig LLP)
Restructuring multinational companies provides ample opportunity for tax planning, and ultimately increasing shareholder value. However, when a U.S. corporation in the chain of ownership owns CFCs, it is important to understand the interplay between Code §§ 367 and 1248, and its impact on the reorganization. Page 2

Foreign Companies Could Lose Tax Breaks in Toll Road Projects
By Keith Martin (Chadbourne & Parke LLP)
Toll road projects in the U.S. have attracted foreign companies, which receive a spacial tax break when they exit the project. A recent proposed change to regulations under Section 897(a) is expected to disqualify some foreign companies from the tax benefit. Page 4

IRS Exchanging Tax Records with Foreign Tax Authorities
By Tamara W. Ashford (Dewey & LeBoeuf LLP)
Accelerated globalization by multinational companies has led the IRS and many foreign tax agencies to increase exchanges of tax information. IRS revenue agents are using the information as an audit tool. Page 3

Bargains for Foreign Buyers, but Tax Planning Essential
By Larissa V. Tkachenko and Elinore J. Richardson (Borden Ladner Gervais LLP)
Canadian tax changes and market conditions have depressed selling prices of businesses owned by Canadian Income Funds, and
foreign buyers see opportunities. But foreign companies need to plan for the particular tax effects of the transactions. Page 5

New Penalties for Taxpayers with Interests in Foreign Corporations
By William F. Roth (BDO Seidman, LLP)
The IRS announced it will impose stiff penalties for late filers of Forms 1120 with Forms 5471 attached, beginning on January 1. Taxpayers with interests in foreign corporations or those who hold officer or director positions in foreign corporations should take note. Page 6

Restrictions on Loans from CFCs to U.S. Parent Companies Relaxed
By Edward Tanenbaum and Diana Wessells (Alston & Bird LLP)
The measure is designed to provide U.S. companies with a source of fi nancing during the financial crisis.  Because of uncertainties over the change, some tax specialists are calling for clarification or establishment of a safe harbor. Page 2

Saving Taxes by Channeling Investments to Latin America through Spain
By Victor Cabrera, Antonio Lobon and Marc Skaletsky (KPMG LLP)
Spain’s holding company regime offers tax benefi ts to U.S. and other multinational corporations that are investing in Latin America. An examination of the structure, tax treaty network and other advantages. Page 3

Taxes Could Increase for Foreign Investors in U.S. Infrastructure Projects
By Rafic H. Barrage, James R. Barry, Jason S. Bazar, Jeffrey M. Bruns, Robert A. Kelman, Kenneth Klein and Jonathan A. Sambur (Mayer Brown LLP)
Foreign partnerships that own U.S. companies could face higher taxes if a recently proposed rule goes into effect. The changes to the FIRPTA provisions of the code would clarify the fair market value of government permits to operate infrastructure projects, such as toll roads and toll bridges. Page 4

Canada--Fifth Protocol to U.S.-Canada Tax Treaty: Fiscally Transparent Entities Beware!
By Elinore Richardson and Stephanie Wong (Borden Ladner Gervais LLP)
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