This index of articles published in Practical U.S./International Tax Strategies in 2001 is provided for your convenience. Articles are grouped by subject matter. Under each subject heading, articles are listed chronologically by month, day and page number.

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Accounting

Audits

FSAs Take Hard Line on Drafting Cost- Sharing Arrangements; Avoiding Problems on Audit, Part II 7/31-1

Audit Guidelines for Qualified Intermediaries 12/20-3

Compliance Update

The Fallout from FAS 133; Should Congress Change Tax Law to Match New Accounting Standards? 2/28-1

Planning Notes for US Businesses Operating Overseas; US Outbound Tax Issues 5/31-3

IRS Targets "Basis-Shifting" Tax Shelters; Transactions Involving Foreign Subsidiaries Challenged 7/31-3

US Treasury/IRS Provide Relief for Victims of Attacks 9/15-20

Businesses Can E-mail Disaster Questions to IRS 9/30-20

Implementing the New Withholding and Reporting Rules 10/31-3

Audit Guidelines for Qualified Intermediaries 12/20-3

Controlled Foreign Corporations

CFC Rules Proliferate 11/15-1

Cross-Border Finance/Transactions

International Tax 101; Cliff Notes to Cross-Border Business 1/15-3

International Tax 101; More Cliff Notes to Cross-Border Business 1/31-3

Cross-Border Structured Products; Reconsidering Tax-Efficient Structures Created by Treaty Networks and "Check-the-Box" Regulations 2/15-1

Securitizations of Auto Lease Receivables Face a Tax Problem; Tax Developments in Germany Must be Accommodated 2/28-1

Globalization vs. Taxation; Recent Survey Shows Efforts to Expand Cross-Border Business Are Often Divorced from Tax Planning 3/31-6

Strategies for Structuring Cross-Border Investments in Canadian Companies; Managing Your Exposure to Canadian Taxes 5/15-1

Asset-Backed Securities Transactions; Tax Aspects of Deals in the Asia-Pacific Region 7/31-10

US Companies Financing Subsidiaries in Mexico; Tax Consequences of Choosing Debt and Equity 9/30-3

The Maquiladora Option Today; Use of US-Mexico Border Companies Still Going Strong 9/30-12

Effective Tax Planning: Defending Profitability in Difficult Economic Conditions 10/31-1

Dispute Resolution

IRS Launches "Fast Track" Dispute Resolution Pilot 11/15-7

Domestic Outbound Transactions

Update on Filing Requirements for Transfers of Property Offshore 7/15-3

Electronic Commerce

The US E-Tax Moratorium; It's Not as Simple as it Sounds 3/15-10

Internet Tax Legislation; Congressional Activity Picks Up as End of Moratorium Approaches 5/31-1

Estate Planning

International Estate Planning: The First Step to an Asset Protection Plan 1/15-11

Executive Compensation

Stock Options: Tax Planning Issues in the US and UK; What Happens When Options are Underwater? 1/15-1

Update on Tax Treatment of Stock Options; IRS Rethinks Withholding, SEC Addresses "Rescission" of Exercised Options 1/31-11

International Tax Planning for Highly-

Compensated Individuals; Taking Advantage of Special Treatment for "Rabbi Trusts" 4/15-3

More on International Tax Planning for Highly-Compensated Individuals; Combining Individual Leasing Programs, Deferred Compensation and Rabbi Trusts 4/30-3

Compensatory Stock and Stock Options Granted by PFICs 10/15-1

Export Incentives

How to Claim the New "Extraterritorial Income Exclusion"; IRS Releases Form 8873 for Use in Calculating the Export Tax Benefit 2/28-11

FSC Leases; International Leasing Transactions and Implications of the FSC Repeal 5/31-12

Making Elections under the FSC Repeal and Extraterritorial Income Exclusion Act 6/30-3

An Analysis of the WTO Ruling on the FSC Replacement Act 8/15-7

EU Sounds Conciliatory on Trade Sanctions Against US 9/30-16

US Appeals WTO Ruling on "ETI" Act; Resolution Not Likely Until 2002 10/15-16

Foreign Exchange

US Tax Effects of Conversion to the Euro; And Special Rules for Hyperinflationary Currencies 3/15-1

Taxing Foreign Currency Hedges; US Tax Treatment of Derivative Transactions Involving Foreign Currencies 4/14-1

Foreign Tax Credits

Applying the Foreign Tax Credit Separate Limitation and Deemed Paid Credit Rules, Part I 1/31-13

Applying the Foreign Tax Credit Separate Limitation and Deemed Paid Credit Rules, Part II 2/15-12

"Windfall Profits Tax" and the Foreign Tax Credit 6/30-1

The Taxation of Foreign Joint Ventures and Strategic Alliances, Part II: Foreign Tax Credit Planning and Disposing of a Joint Venture 11/15-1

IRS Releases New "Coordinated Issue Paper" Affecting Foreign Tax Credit Strategy 11/15-3

Foreign Investment

Foreign Investors Look Now Toward Germany 1/15-1

Foreign Sales Corporations (also see Export Incentives)

International Leasing Transactions; Implications of the New US "Extraterritorial Income Exclusion" Regime 2/15-1

Inbound Transactions

The US E-Tax Moratorium; It's Not as Simple as it Sounds 3/15-10

Indirect Taxes

Indirect TaxAn Option for George W. Bush? A US VAT is not Unimaginable 3/15-1

Investment Companies

Mutual Funds to Disclose After-Tax Returns; SEC Adopts New Rules for Funds to Follow 1/31-1

Dealing with Passive Foreign Investment Companies; How the System Works and Strategies to Avoid PFIC Status 3/15-3

More on Dealing with Passive Foreign Investment Companies; Using Inter-Company Loans, Handling Start-Up Costs and Other Matters 3/31-3

IRS Rulings, Regulations, Issues

Update on Tax Treatment of Stock Options; IRS Rethinks Withholding, SEC Addresses "Rescission" of Exercised Options 1/31-11

Applying the Foreign Tax Credit Separate Limitation and Deemed Paid Credit Rules, Part I 1/31-13

Cost-Sharing Rules under IRS Attack, Part IV 2/15-3

Applying the Foreign Tax Credit Separate Limitation and Deemed Paid Credit Rules, Part II 2/15-12

How to Claim the New "Extraterritorial Income Exclusion"; IRS Releases Form 8873 for Use in Calculating the Export Tax Benefit 2/28-11

Common Themes and Recent Developments in International Tax Litigation; Key IRS Procedures, Choosing the Best Forum and the Role of Penalties 4/30-1

Spinning Off Your Real Estate Assets 6/15-1

IRS Targets "Basis-Shifting" Tax Shelters; Transactions Involving Foreign Subsidiaries Challenged 7/31-3

US Treasury/IRS Provide Relief for Victims of Attacks 9/15-20

Businesses Can E-mail Disaster Questions to IRS 9/30-20

IRS Releases New "Coordinated Issue Paper" Affecting Foreign Tax Credit Strategy 11/15-3

IRS Launches "Fast Track" Dispute Resolution Pilot 11/15-7

Leasing

International Leasing Transactions; Implications of the New US "Extraterritorial Income Exclusion" Regime 2/15-1

Legislation/Regulation

Internet Tax Legislation; Congressional Activity Picks Up as End of Moratorium Approaches 5/31-1

Litigation

Common Themes and Recent Developments in International Tax Litigation; Key IRS Procedures, Choosing the Best Forum and the Role of Penalties 4/30-1

Recent Developments in International Tax Litigation Part II: A Review of Some Key Court Opinions 5/15-7

Mergers & Acquisitions

Foreign Investors Look Now Toward Germany 1/15-1

Checklist of Transfer Pricing Issues For M&A Transactions Involving US Targets 3/31-1

Transfer Pricing and M&A Transactions Involving US Targets, Part II; Documentation and Disclosure Issues to Consider 4/15-1

Canadian Tax Issues in Foreign Mergers; Issues for Shareholders and Merged Corporations 5/31-1

Overview of Mergers and Acquisitions; A Primer on the Tax Consequences, Part I 6/15-1

Overview of Mergers and Acquisitions, Part II; A Primer on the US Tax Consequences 6/30-1

Multinational Tax Issues

US International Tax Policy Called Outdated 12/20-1

Operational Structure

Swiss Corporate Ventures, Inc.; "Timeshares and Tax Breaks" Advantages of Establishing a Holding Company in Switzerland 2/28-3

Getting Started in Germany; Choosing the Form of Organization and Optimum Capital Structure under the New Tax Law 7/15-1

The "Principal International Company" Global Corporate Tax Reduction Opportunities 10/15-3

Outbound Transactions

International Tax 101; Cliff Notes to Cross-Border Business 1/15-3

International Tax 101; More Cliff Notes to Cross-Border Business 1/31-3

Planning Notes for US Businesses Operating Overseas; US Outbound Tax Issues 5/31-3

Shifting Intangible Income to an Offshore Company 8/15-3

Shifting Intangible Income to an Offshore Company, Part II: Sale or License? 9/15-3

Issues in the Taxation of Foreign Joint Ventures and Strategic Alliances 10/31-1

The Taxation of Foreign Joint Ventures and Strategic Alliances, Part II: Foreign Tax Credit Planning and Disposing of a Joint Venture 11/15-1

Taxation of Foreign Joint Ventures and Strategic Alliances, Part III: Entity Classification, "Check-the-Box" and

De Facto Partnerships 11/30-3

Passive Foreign Investment Companies

Dealing with Passive Foreign Investment Companies; How the System Works and Strategies to Avoid PFIC Status 3/15-3

More on Dealing with Passive Foreign Investment Companies; Using Inter-

Company Loans, Handling Start-Up Costs and Other Matters 3/31-3

Planning Advisory

International Tax 101; Cliff Notes to Cross-Border Business 1/15-3

International Tax 101; More Cliff Notes to Cross-Border Business 1/31-3

Cost-Sharing Rules under IRS Attack, Part IV 2/15-3

Dealing with Passive Foreign Investment Companies; How the System Works and Strategies to Avoid PFIC Status 3/15-3

More on Dealing with Passive Foreign Investment Companies; Using Inter-

Company Loans, Handling Start-Up Costs and Other Matters 3/31-3

Planning Notes for US Businesses Operating Overseas; US Outbound Tax Issues 5/31-3

Want a Multinational Corporation in Your Backyard? Strategic Tax Planning for Countries Without a Clue 6/15-3

Making Elections under the FSC Repeal and Extraterritorial Income Exclusion Act 6/30-3

Shifting Intangible Income to an Offshore Company 8/15-3

Shifting Intangible Income to an Offshore Company, Part II: Sale or License? 9/15-3

The "Principal International Company" Global Corporate Tax Reduction Opportunities 10/15-3

IRS Releases New "Coordinated Issue Paper" Affecting Foreign Tax Credit Strategy 11/15-3

Real Property

Spinning Off Your Real Estate Assets 6/15-1

Consolidated Return Rules Updated to Reflect US Direct Ownership of Mexican Real Estate 7/31-12

Regulatory Developments

Bush Stops Regulations Made in Clinton's Final Days 1/31-1

Royalties

Canadian Supreme Court Clarifies Treatment of Royalties for Customs Valuation Purposes 6/16-13

Securities

Stock Options: Tax Planning Issues in the US and UK; What Happens When Options are Underwater? 1/15-1

Mutual Funds to Disclose After-Tax Returns; SEC Adopts New Rules for Funds to Follow 1/31-1

Update on Tax Treatment of Stock Options; IRS Rethinks Withholding, SEC Addresses "Rescission" of Exercised Options 1/31-11

Asset-Backed Securities Transactions; Tax Aspects of Deals in the Asia-Pacific Region 7/31-10

Compensatory Stock and Stock Options Granted by PFICs 10/15-1

Tax Planning

Stock Options: Tax Planning Issues in the US and UK; What Happens When Options are Underwater? 1/15-1

Globalization vs. Taxation; Recent Survey Shows Efforts to Expand Cross-Border Business Are Often Divorced from Tax Planning 3/31-6

International Tax Planning for Highly-

Compensated Individuals; Taking Advantage of Special Treatment for "Rabbi Trusts" 4/15-3

More on International Tax Planning for Highly-Compensated Individuals; Combining Individual Leasing Programs, Deferred Compensation and Rabbi Trusts 4/30-3

US Strategic Tax Planning and Other Modern Day X Files; An FSA to Remember 5/15-3

Tax Shelters

IRS Targets "Basis-Shifting" Tax Shelters; Transactions Involving Foreign Subsidiaries Challenged 7/31-3

Business Purpose Doctrine Given Broad Interpretation 8/15-1

Corporate Tax Shelter Regs Alter International Tax Landscape 9/30-1

New Disclosure Initiative on Tax Shelters 12/20-15

Tax Treaties

Cross-Border Structured Products; Reconsidering Tax-Efficient Structures Created by Treaty Networks and "Check-the-Box" Regulations 2/15-1

Swiss Corporate Ventures, Inc.; "Timeshares and Tax Breaks" Advantages of Establishing a Holding Company in Switzerland 2/28-3

US and UK Sign New Income Tax Treaty 8/15-9

Implementing the New Withholding and Reporting Rules; Part II: Disclosing Treaty-Based Return Positions 10/15-1

US and Luxembourg Agree on Interpretation of Treaty Rules 11/15-15

US Tax Treaty with Venezuela reviewed by Court 11/30-1

Transfer Pricing

Cost-Sharing Rules under IRS Attack, Part IV 2/15-3

Checklist of Transfer Pricing Issues For M&A Transactions Involving US Targets 3/31-1

Proper Documentation of Transfer Pricing Practices; Distinguishing Between "Principal" and "Background" Documents and Avoiding Potential US Tax Penalties 3/31-1

Transfer Pricing and M&A Transactions

Involving US Targets, Part II; Documentation and Disclosure Issues to Consider 4/15-1

A Comparative Analysis of Transfer Pricing Documentation Requirements; How the US, Canada and Selected European Countries Handle the Issue 4/15-10

Competent Authority to Avoid Double or Excessive Taxation from Transfer Pricing Adjustments; Strategy for Competent Authority Cases 4/30-1

A Comparative Analysis of Transfer Pricing Documentation Requirements, Part II; How the US, Canada and Selected European Countries Handle the Issue 4/30-7

Competent Authority to Avoid Double or Excessive Taxation from Transfer Pricing Adjustments, II; Results, Concerns for the Future and Adverse Effects 5/15-1

FSAs Take Hard Line on Drafting Cost Sharing Arrangements 7/15-1

Transfer Pricing Circa 2001; Assessing the Current Environment, Part I 7/31-1

FSAs Take Hard Line on Drafting Cost Sharing Arrangements; Avoiding Problems on Audit, Part II 7/31-1

Transfer Pricing Circa 2001, Part II: Audits, Controversies and Penalties 8/15-1

US Distribution Companies Can Present Difficult Transfer Pricing Issues 9/15-1

Transfer Pricing Circa 2001, Part III: Strategies for Resolving Disputes 9/15-1

KPMG Launches New Software to Manage Transfer Pricing Process 9/30-8

Transfer Pricing Remains Most Important International Tax Issue 11/30-1

"Hot Issues" from the New Transfer Pricing Survey 12/20-1

Withholdings

More Guidance on Implementing the New Withholding and Reporting Rules; Part I: A Temporary, Alternative Procedure for 2001 9/30-1

Implementing the New Withholding and Reporting Rules; Part II: Disclosing Treaty-Based Return Positions 10/15-1

Partial Mexican Withholding Tax Refund Possible on Dividends Distributed to US Companies 10/15-8

Implementing the New Withholding and Reporting Rules 10/31-3

Snapshots, a regular feature of Practical U.S./International Tax Strategies, has not been indexed. More information can be obtained by referring to individual issues.