Two months after announcing plans to address certain "inappropriate foreign tax credit transactions," (see International Tax Review, US Outbound Update, April 2004, p97), the US Treasury Department and the Internal Revenue Service (IRS) issued long-anticipated temporary and proposed regulations governing partnership allocations of creditable foreign taxes under Internal Revenue Code section 704(b). Under these regulations, an allocation of creditable foreign taxes cannot have substantial economic effect and as such the taxes must be allocated in accordance with the partners' interests in the partnership.
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The US president also unveiled a new 50% levy on copper imports; in other news, a UK wealth tax proposal has been criticised by the Institute for Fiscal Studies
MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process