Author Tax Policy Group, Deloitte Tax LLP
Offshore Deferred Comp Restrictions, Delay in Worldwide Interest Allocation Resurrected to Pay for Ways & Means Extenders Bill – House taxwriters approved provisions that would tighten rules regarding offshore deferred compensation and delay the effective date of the worldwide interest allocation election to pay for legislation that would provide one-year extensions of dozens of corporate and individual tax provisions that expired at the end of 2007 or are scheduled to expire at the end of this year. Internal Revenue Service (IRS) Offers Market-Related Relief for Securities Dealers – The IRS issued a revenue procedure that offers temporary relief under section 956(c)(2)(J) for U.S. securities dealers that have secured borrowings from their controlled foreign corporations effected through sale and repurchase agreements or other collateralized borrowings involving readily marketable securities. House OKs High-Income Surtax in Iraq Supplemental Spending Legislation; Bush Promises Veto – The House of Representatives approved an Iraq War supplemental spending bill (H.R. 2642) that would pay for a package of veterans’ education benefits by imposing a surtax on certain high-income individual taxpayers, but long-term prospects for the bill are poor.
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