Tax News & Views, published by the Deloitte Tax LLP Tax Policy Services group in Washington, D.C., provides a compact, reader-friendly perspective on the latest corporate tax developments coming out of Congress, the Internal Revenue Service (IRS), the Department of the Treasury and the federal courts.

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July 18, 2008
New Foreign Tax Credit Regs Address Structured Passive Investment Arrangements

• New Foreign Tax Credit Regs Address Structured Passive Investment Arrangements – The IRS released temporary regulations addressing the requirement for a payment of foreign taxes to be "compulsory" in order to be creditable, by treating taxes attributable to certain highly structured passive arrangements as noncompulsory.
• Rules Finalized on Phantom REMIC Income Allocable to Foreign Partners – The IRS adopted 2006 temporary regulations that require U.S. partnerships to withhold tax, under sections 1441 and 1442, on foreign partners' shares of "phantom income" from a domestic partnership's residual interest in a real estate mortgage investment conduit.
• Guidance on Transfers from a Qualified Plan to a Foreign Trust Includes Transition Relief – The IRS recently ruled that a transfer from a plan qualified under Internal Revenue Code section 401(a) to a nonqualified foreign trust constitutes a taxable distribution; but in light of the potentially severe negative consequences for qualified plans that previously made transfers to nonqualified foreign trusts, the Service has provided some fairly generous transition relief.
• Housing Stimulus Legislation On Tap in House – The House of Representatives is slated to consider Senate-approved comprehensive housing stimulus legislation (H.R. 3221) the week of July 21 with a 10-year, $14.5 billion tax incentives package that is partially offset by revenue raisers.
• Senate Subcommittee Considers Role of Tax Haven Banks in U.S. Tax Evasion – The Senate Homeland Security and Governmental Affairs Permanent Subcommittee on Investigations held a hearing to examine how financial institutions located in offshore tax havens may be engaged in banking practices that could facilitate, and in some instances have resulted in, tax evasion and other misconduct by U.S. clients.

July 11, 2008
IRS Ruling Describes Treatment of Fund of Hedge Funds Expenses

• IRS Ruling Describes Treatment of Fund of Hedge Funds Expenses – The IRS issued a revenue ruling addressing the treatment of expenses incurred by a fund of funds in connection with its activities of investing in a series of underlying funds, which were themselves managed by third parties.
• Senate Clears Comprehensive Housing Stimulus Legislation – The Senate approved comprehensive housing stimulus legislation with a 10-year, $14.5 billion tax incentives package that is partially offset by revenue raisers, including a proposal to require information reporting on credit card transactions.
• Regs Provide Deemed Election to Deduct Start-Up or Organizational Expenditures – The IRS released final, temporary, and proposed regulations on elections to deduct start-up expenditures under section 195, corporate organizational expenditures under section 248 and partnership organizational expenditures under section 709.
• New Regs Shorten Extended Filing Period for Certain Passthrough Returns – Recently released final, temporary, and proposed regulations change the extended due date on certain passthrough business returns, reducing the extension period from six to five months.
• Baucus to Introduce New Extenders, AMT Legislation; Timing Uncertain – Senate Finance Committee Chairman Max Baucus, D-Mont., told reporters that he intends to introduce revised legislation to extend expired or expiring tax provisions and patch the individual alternative minimum tax, but was unclear on his timetable.
• House-Approved Pension Technical Corrections Bill Includes Asset Smoothing Provision – The House approved a pension technical corrections bill that includes a clarification of Congress's intent to preserve two-year asset smoothing in the calculation of the value of pension assets.

July 7, 2008 - Special Edition
Housing Stimulus, Extenders Top Post-Recess Congressional Agenda; Prospects for Fast Action Uncertain

June 27, 2008
Senate Housing Stimulus Bill Stalls Due to Energy Spat; Post-Recess Action Expected

June 25, 2008 - Special Edition
House Approves Carried Interest Tax Hike to Pay for AMT Patch; White House Threatens Veto

June 20, 2008
Senate Mulls Revamped Housing Stimulus Tax Package: Extended NOL Carryback Out, Revenue Offsets In

June 18, 2008 - Special Edition
House Taxwriters OK Fully Offset AMT Patch; Prospects Dim in Senate

June 17, 2008 - Special Edition
Tougher Expat Tax Rules Enacted to Pay for Military Tax Relief

June 13, 2008
Senate Extenders, Energy Bills Stall as Democrats and GOP Draw Lines in the Sand Over Offsets

June 6, 2008
Baucus: Senate Extenders Bill to Bypass Finance Committee; Floor Consideration Likely Next Week

May 30, 2008
Congress Preps for Busy Post-Recess Schedule Prior to Even Busier Campaign Season

May 23, 2008
Senate Approves Tighter Expatriation Tax Rules in Military Tax Relief Bill; Next Stop, White House

May 21, 2008 - Special Edition
House OKs Energy & Extenders Bill; Revenue Offsets Prompt White House Veto Threat 

May 20, 2008 - Special Edition
House Approves Tougher Expat Tax Rules to Bankroll Military Tax Relief Legislation 

May 15, 2008
Offshore Deferred Comp Restrictions, Delay in Worldwide Interest Allocation Resurrected to Pay for Ways & Means Extenders Bill

May 8, 2008
House Approves Housing Assistance Package Paid for by Basis Reporting, Delay in Worldwide Interest Allocation Election

May 2, 2008
Senate Aviation Bill Hits Turbulence as Republicans Criticize Revenue Raisers

April 25, 2008
Déjà Vu All Over Again as Lawmakers Extend Farm Bill

April 18, 2008
Baucus, Grassley Introduce Tax Extenders Package

April 10, 2008 - Special Edition
Senate Passes Housing Stimulus Proposal; Includes Four-Year NOL [Net Operating Loss] Carryback and Renewable Energy Tax Package 

April 9, 2008 - Special Edition
Ways & Means OKs Basis Reporting, Delay in Worldwide Interest Allocation Election to Pay for Housing Assistance Bill 

April 4, 2008
Senate Reaches Compromise on Housing Stimulus Proposal; Includes Four-Year NOL Carryback

March 28, 2008
Budget Reconciliation, Energy and Housing Stimulus Legislation on Tap as Congress Returns from Recess

March 14, 2008
House and Senate Clear Budget Blueprints

March 7, 2008
Congressional Committees Approve FY 2009 Budget Resolutions

February 29, 2008
Post-Recess Tax Agenda Moving in Fits and Starts

February 22, 2008
High Court Rules Employees Can Sue for Employer Misconduct Resulting in Individual 401(k) Losses

February 15, 2008
Stimulus Legislation Becomes Law; Senate Plans Second Bill

February 7, 2008 - Special Edition
House, Senate OK Compromise Stimulus Deal; Next Stop – White House 

February 4, 2008 - Special Edition
President's Proposed Budget Expands Tax Gap Proposals; Renews Call for Permanent Tax Cuts, Savings and Health Care Incentives 

February 1, 2008
Senate to Act on $158 Billion Stimulus Package as GOP Expresses Misgivings

January 30, 2008 - Special Edition
Senate Taxwriters Approve $158 Billion Stimulus Package 

January 25, 2008
Bush, House Leaders Agree on Stimulus Tax Relief for Businesses, Individuals; Senate Taxwriters Plan Separate Bill