Monthly Archives: August 2010

Thomson Reuters/WG&L International Tax Title of the Week. “U.S. Transfer Pricing Developments“ above reports on the IRS’s acquiescence in the Xilinx case. The lead article in the forthcoming September issue of Journal of International Taxation will include an in-depth analysis … Continue reading →

Privilege in Uncertain Tax Position Matters. An IRS official indicated that the Service hopes to address concerns about privilege and Schedule UTP [BNA Daily Tax Report, July 30, 2010, page G-8; Lowell & Martin: U.S. International Taxation: Practice and Procedure … Continue reading →

Senate-passed bill closes foreign tax credit loopholes, ends advanced EITC. On August 5, the Senate by a vote of 61-39 approved H.R. 1586, which includes provisions closing a number of foreign-tax-credit related loopholes and repealing the advanced earned income tax … Continue reading →

IRS’s LMSB Division to become the Large Business and International Division. IRS has announced that its Large and Mid-Size Business (LMSB) division will change on Oct. 1 to the Large Business and International (LB&I) Division. The change its part of … Continue reading →

States looking to minimize deficits are increasingly attempting to impose sales tax on online retailers. This is a great summary of far-reaching sales tax legislation impacting online retailers:  http://www.newrules.org/retail/rules/internet-sales-tax-fairness

IRS rejects Ninth Circuit’s reasoning in Xilinx but acquiesces in result (AOD 2010-003,07/28/2010) IRS has issued an action on decision (AOD) concerning the Ninth Circuit’s much heralded decision in Xilinx Inc. and Subsidiaries, (CA 9 3/22/2010) 105 AFTR 2d ¶ … Continue reading →

Senate slated to consider education jobs bill with foreign-related tax offsets. On August 2, the Senate was scheduled to vote on the motion to concur in the House amendment to the Senate amendment to H.R. 1586 with the Reid amendment … Continue reading →

D.C. Circuit finds work product protection not waived by disclosure to independent auditor The U.S. Court of Appeals for the District of Columbia Circuit on June 29 held (3-0) that work product doctrine protection is not waived by disclosure of … Continue reading →