IRS revises its approach to transfers of stock to foreign corporations in exchange for property, saying that gain might be recognized on the deemed transfer of shares.

IRS provides taxpayers with an exclusive list of deals it would consider to be foreign tax credit splitter arrangements in long-anticipated proposed and temporary regulations (REG-132736-11, T.D. 9577). In addition, IRS finalizes, in T.D. 9576, portions of 2006 proposed rules (REG-124152-06) on determining who is considered to pay a foreign income tax.

Taxpayers wanting to glean some insight into the way the Internal Revenue Service plans to enforce its new cost sharing regulations should pay close attention to the language in the preamble to the document, John M. Peterson Jr., of Baker & McKenzie in Palo Alto, Calif., told Bloomberg BNA Jan. 31.

An initiative by the Organization for Economic Cooperation and Development to revisit its definition of "intangibles" for transfer pricing purposes likely will lead to language that is broader than legal or accounting definitions of the concept—but not so broad as to encompass a number of variables that could not be legally protected, a former OECD official said Jan. 27.

New Russian transfer pricing rules that took effect Jan. 1 are largely based on guidelines of the Organization for Economic Cooperation and Development, but owing to their interaction with domestic tax law, they also contain some "peculiarities" that can trigger transfer pricing for both unrelated companies and related companies operating only within Russia, a practitioner in Moscow said Jan. 27.

Banks in foreign jurisdictions and the United States get sweeping guidance on the next major phase of implementation of the Foreign Account Tax Compliance Act, in nearly 400 pages of eagerly-awaited rules (REG-121647-10) that practitioners say show positive responses to industry concerns.

IRS Commissioner Shulman refuses to condemn mutual funds for using offshore entities to avoid U.S. tax rules governing investments in commodities, saying he disagrees with senators that the actions were akin to other types of tax avoidance that the agency has been aggressively trying to end.

Taxes will be required to be withheld on any payments of “dividend equivalents” to nonresident aliens and foreign corporations as a way to crack down on certain tax avoidance practices, IRS says in temporary (T.D. 9572) and proposed (REG-120282-10) rules.

IRS issues temporary and proposed regulations (T.D. 9571, REG-113903-10) providing guidance on the allocation and apportionment of interest expense by corporations owning a 10 percent or greater interest in a partnership.

IRS's sharply increased focus on international tax enforcement is taking place without adequate servicewide coordination or help for taxpayers trying to comply with myriad confusing rules, IRS Taxpayer Advocate Nina Olson says in a report.