tax notes international - Tuck School of Business - Dartmouth College

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Office of Associate Chief Counsel (Income Tax and Accounting) discussed proposals that had been rejected in the course of developing the rules. He said the drafters considered and received comments on including a substantial contribution safe harbor, but decided not to adopt the safe harbor because of the ‘‘broad range of activities covered by the regulations’’ preventing the creation of an appropriate rule. Mitchell added that the IRS rejected including an antiabuse provision that would have precluded CFCs from meeting the substantial contribution test if a related person had significant involvement in the production process. ‘‘We decided that the CFC’s contribution really should be evaluated on its own and we ultimately decided that even more than one person could make a substantial contribution,’’ Mitchell said. ‘‘If another party makes a contribution to the manufacturing process, it doesn’t preclude the CFC from having a substantial contribution.’’ ♦ David D. Stewart, Tax Analysts. E-mail: dstewart@tax.org CORRECTION An article in the January 26, 2009, issue of Tax Notes International (‘‘U.S. Tax Returns for Foreign Nationals,’’ p. 337) contained an error. On p. 340, in the section titled ‘‘Disclosure Requirements,’’ references to Schedule A should be to Schedule B. Tax Analysts regrets the error. UNITED STATES TAX NOTES INTERNATIONAL FEBRUARY 2, 2009 • 409 (C) Tax Analysts 2009. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content.
410 • FEBRUARY 2, 2009 TAX NOTES INTERNATIONAL (C) Tax Analysts 2009. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content.
Page 1 and 2: tax notes international Volume 53,
Page 3 and 4: ARGENTINA 387 Buenos Aires’ New S
Page 5 and 6: President and Publisher: Christophe
Page 7 and 8: HIGHLIGHTS from the tax accounts in
Page 9 and 10: HIGHLIGHTS However, if the firm rec
Page 11 and 12: HIGHLIGHTS NEWS ANALYSIS Multinatio
Page 13 and 14: HIGHLIGHTS check by full tax on any
Page 15 and 16: HIGHLIGHTS U.S. Widens Investigatio
Page 17 and 18: HIGHLIGHTS is required to withhold
Page 19 and 20: HIGHLIGHTS by a Canadian taxpayer a
Page 21 and 22: HIGHLIGHTS Personal Tax Measures Th
Page 23 and 24: ARGENTINA the most significant exem
Page 25 and 26: CHINA (P.R.C.) On December 16, 2008
Page 27 and 28: EUROPEAN UNION ensure that there is
Page 29 and 30: GERMANY confessed to his wrongdoing
Page 31 and 32: INDIA Addressing the assessee’s d
Page 33 and 34: INDONESIA As of January 1 and conti
Page 35 and 36: JAPAN insistence that the bill incl
Page 37 and 38: OECD OECD OECD Group Addresses CIVs
Page 39 and 40: OECD Furthermore, a source country
Page 41 and 42: PORTUGAL Extension of Portuguese Ho
Page 43: SPAIN tax authorities interpret the
Page 47 and 48: FEATURED PERSPECTIVES We, the taxpa
Page 49 and 50: FEATURED PERSPECTIVES he has to pay
Page 51 and 52: BOOK REVIEW smaller government. But
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Page 55 and 56: PRACTITIONERS’ CORNER for German
Page 57 and 58: SPECIAL REPORTS reports were of the
Page 59 and 60: SPECIAL REPORTS that either avoids
Page 61 and 62: SPECIAL REPORTS U.S. Germany Switze
Page 63 and 64: SPECIAL REPORTS The operations carr
Page 65 and 66: SPECIAL REPORTS the profits that ma
Page 67 and 68: SPECIAL REPORTS In essence, the fir
Page 69 and 70: SPECIAL REPORTS Figure 6. Single Ta
Page 71 and 72: SPECIAL REPORTS Table 1. Comparison
Page 73 and 74: SPECIAL REPORTS Singapore India pre
Page 75 and 76: SPECIAL REPORTS such a case, the tr
Page 77 and 78: SPECIAL REPORTS If the single taxpa
Page 79 and 80: SPECIAL REPORTS agent would be as i
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Page 83 and 84: SPECIAL REPORTS create unintended b
Page 85 and 86: SPECIAL REPORTS country of organiza
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Page 89 and 90: SPECIAL REPORTS manufacturing is th
Page 91 and 92: SPECIAL REPORTS FS A B C Designs X
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SPECIAL REPORTS the intangible deve
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SPECIAL REPORTS In Example 3, the f
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SPECIAL REPORTS The investor model
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SPECIAL REPORTS The licensing alter
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SPECIAL REPORTS The second exceptio
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SPECIAL REPORTS provides the most r
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SPECIAL REPORTS The taxpayer assert
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SPECIAL REPORTS the elimination of
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TAX CALENDAR financially distressed
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Africa: Zein Kebonang Albania: Adri
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tax notes international - Tuck School of Business - Dartmouth College

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