https://www.taxtmi.com/news?id=836 The proposal limits deductions tied to untaxed foreign profits by deferring domestic deductions until foreign earnings are taxed in the U.S. (except R&E), reforms the foreign tax credit to reflect actual foreign taxes on total foreign earnings and disallow credits for income not subject to U.S. tax, requires certain foreign subsidiaries to be treated as corporations for U.S. tax purposes to prevent income shifting to tax havens, strengthens the Qualified Intermediary regime with withholding and evidentiary presumptions for non cooperative institutions, increases reporting and penalties for foreign accounts, extends international enforcement limitation periods, and funds enhanced IRS international enforcement. en-us Tue, 05 May 2009 17:05:39 +0530 Tue, 05 May 2009 21:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/news?id=836 The proposal limits deductions tied to untaxed foreign profits by deferring domestic deductions until foreign earnings are taxed in the U.S. (except R&E), reforms the foreign tax credit to reflect actual foreign taxes on total foreign earnings and disallow credits for income not subject to U.S. tax, requires certain foreign subsidiaries to be treated as corporations for U.S. tax purposes to prevent income shifting to tax havens, strengthens the Qualified Intermediary regime with withholding and evidentiary presumptions for non cooperative institutions, increases reporting and penalties for foreign accounts, extends international enforcement limitation periods, and funds enhanced IRS international enforcement. News - Tue, 05 May 2009 17:05:39 +0530 https://www.taxtmi.com/news?id=836