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      Martin B. Tittle  
        International Tax Attorney
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Martin B. Tittle

(734) 846-3864



P.O. Box 1541
Ann Arbor, MI 48103


*You should be very cautious about the information you reveal in an initial contact or inquiry. I have no duty to keep confidential any information that is communicated to me before you sign an engagement agreement.



  • * Sept. 23, 2014: from IRS Guidewire: "Notice 2014-52 describes regulations that the IRS and Treasury Department intend to issue with respect to inversion transactions. Such regulations will (i) for purposes of section 7874, disregard certain stock of a foreign acquiring corporation that holds a significant amount of passive assets; (ii) for purposes of sections 7874 and 367, disregard certain non-ordinary course distributions; (iii) for purposes of section 7874, provide guidance on the treatment of certain transfers of stock of a foreign acquiring corporation (through a spin-off or otherwise) that occur after an acquisition; (iv) prevent the avoidance of section 956 through post-inversion acquisitions by controlled foreign corporations (CFCs) of obligations of (or equity investments in) the new foreign parent corporation or its non-CFC foreign affiliates; (v) prevent the avoidance of U.S. tax on pre-inversion earnings and profits of CFCs through post-inversion transactions that otherwise would terminate the CFC status of foreign subsidiaries and/or substantially dilute the U.S. shareholde's interest in those earnings and profits; and (vi) limit the ability to remove untaxed foreign earnings and profits of CFCs through related party stock sales subject to section 304.
    Notice 2014-52 will appear in IRB 2014-42 dated Oct. 14, 2014."
  • Sept. 8, 2014: U.S. Treasury Secretary Jacob Lew spoke earlier today at a presentation hosted by the Urban-Brookings Tax Policy Center. The title of the program was "Business Tax Reform: What Can Be Done?" Secretary Lew's remarks are available here. One of the panel members, Stephen Shay, wrote persuasively last summer about non-legislative options for curtailing corporate inversions. See "Mr. Secretary, Take the Tax Juice Out of Corporate Expatriations," published by TaxAnalysts.
  • July 23, 2014: A toe-hold for individuals with international compliance questions is available on the Taxpayer Advocate Service's "Resources for International Taxpayers" web page.
  • July 12, 2014: The Intergovernmental Agreement (IGA) between Canada and the United States for the enhanced exchange of tax information under the Convention between Canada and the United States with Respect to Taxes on Income and on Capital entered into force on June 27, 2014.
  • June 30, 2014: On June 27, 2014, Treasury and the IRS published a revised Qualified Intermediary (QI) agreement in Revenue Procedure 2014-39, 2014-29 I.R.B. 151. Entities are encouraged to obtain or renew the QI Agreement by July 31, 2014.
  • June 24, 2014: The IRS announced Rev. Proc. 2014-38 today, saying "Revenue Procedure 2014-38 updates the Model FFI Agreement applicable to foreign financial institutions (FFIs) wishing to enter into an FFI Agreement with the IRS to be treated as a participating FFI under section 1471(b) of the Code. Rev. Proc. 2014-38 also provides guidance to FFIs and branches of FFIs treated as reporting financial institutions under an applicable Model 2 intergovernmental agreement (IGA) on complying with the terms of the FFI Agreement, as modified by the Model 2 IGA. Rev. Proc. 2014-38 updates the Model FFI Agreement to reflect the temporary regulations released on February 20, 2014, under chapters 3, 4, and 61 of the Code, and section 3406. Rev. Proc. 2014-38 modifies and supersedes Rev. Proc. 2014-13.
    Revenue Procedure 2014-38 will appear in the Internal Revenue Bullentin, IRB 2014-29, dated July 14, 2014."
  • Feb. 5, 2014: Documents related to the U.S.-Canada FATCA agreement signed in Ottawa today are available here.
  • Jan. 21, 2014: Today, the New York State Bar Association Tax Section submitted its report to the IRS and Treasury regarding guidance implementing Rev. Rul. 91-32. As noted in the cover letter accompanying the report, Rev. Rul. 91-32 "addresses the tax consequences of the disposition of a foreign partner's interest in a partnership that conducts a trade or business through a fixed place of business or has a permanent establishment in the United States (an 'ECI Partnership')."
  • Jan. 7, 2014: The NYSBA Tax Section has published its Report No. 1295. This report addresses the FATCA Final Regulations under Sections 1471 through 1474 of the Internal Revenue Code: PFFI ["Participating Foreign Financial Institution"] Rules; IGAs ["Intergovernmental Agreements"]; Interaction Between the Regulations and Chapters 3 and 61.




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