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Makes various observations concerning the Revenue Reconciliation Act of 1993 (RRA). Impact of international provisions on planning, transaction and compliance costs; Foreign investment taxation under controlled foreign corporations (CFC); Excess passive assets; Transfer pricing initiative of the Clinton administration. INSETS: New Section 936 credit computation requires review of..;It might pay to reorganize CFC groups..

The article shows a tax advisory for investors that own stocks and shares in passive foreign investment businesses like mutual funds and partnerships due to them having over 30 percent hike in tax rates, as stated by the Motley Fool.

The article discusses the U.S. Securities and Exchange Commission's (SEC) concerns about large multinational companies' lack of transparency regarding foreign taxes. Topics covered include entertainment company Walt Disney's reclassification of some foreign income as exempt from U.S. taxes in 2012, strategies allowing U.S. multinational companies to reduce taxable income, and difficulties that investors face when predicting corporate earnings.

The article offers information on general tax issues to consider by small and midsized businesses (SMB), Subchapter S corporations and limited liability companies treated as a flow-through entity, in planning an international expansion. Topics discussed include determining whether the foreign presence of a U.S. business provides a permanent establishment in the foreign country and taxation of foreign earnings.

The article reports on a campaign against the U.S. Internal Revenue Service's proposed regulation for reporting interest paid on nonresident aliens' deposits. U.S. Representative Bill Posey, a Republican from Florida, opposes the idea because it will drain foreign capital from the American economy. Banking industry lobbyists also oppose the idea because it might place foreign depositors at risk in their home countries.

The article offers the author's insights on the benefits of tax breaks on qualified small business stock (QSBS) and real estate investment trusts (REITs). The author says that the tax breaks were made permanent by the U.S. Congress in 2015 to some QSBS. He mentions the benefits for foreign clients investing in the REITs in the country by owning up to 10% of a REIT and tax exception.

Discusses the personal judgment exercised by tax lawyers in the United States when handling offshore loan investment practices. Inadequate guidance from the Internal Revenue Service; Debate on the classification of an offshore investor as a loan originator; Elements of offshore investors in the U.S. loan market.

Public-private partnerships may become an important tool for transportation financing, but must overcome political and social hurdles in the U.S. [ABSTRACT FROM AUTHOR]

In this article, the author discusses the implications of the proposal introduced by the U.S. Department of Treasury which requires all banks situated in the U.S. to report interest payments to non-resident alien depositors. He argues that the proposal is wrong at the wrong time, mentioning that the U.S. greatly benefit from the deposits of foreigners. He says that the U.S. Internal Revenue Service (IRS) has failed to conduct a feasibility study regarding the impact of the said proposal.

Reports the protest of the financial services industry on the regulatory proposal of the government regarding taxation of foreign deposits in the U.S. Impact of the proposal to the economy of the country; Concern over the liquidity and safety of banks with foreign deposits; Request of the industry to assess the effect of the proposal.

Reports on the compulsory filing by Americans with foreign investment income applications for Form 6166, Certification for Filing a Tax Return, with the IRS Philadelphia Service center regardless of where their last income tax return was filed. Address for obtaining the form.

Cites the operational problems caused by the Internal Revenue Service's changes to regulations on how United States banks and brokerages calculate withholding of taxes on foreign investors. Need to redesign existing operating systems to accommodate the different rules; Burden of compliance on the foreign institutions; Aspects of current regulations.

Presents ways for international investors to avoid paying United States taxes. Offshore mutual funds considered by Internal Revenue Service; Several popular domiciles of offshore mutual funds; Reason of Fidelity International to register mutual funds in Luxembourg.