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Yearly Archives: 2012

Bearer Notes – Non Deductible, Ordinary Income Rates and Not Qualify as Portfolio Debt.

Notice 2012-20 provides guidance relating to the portfolio interest exception, the short term debt exception under section 1.6049-5(b)(10), and the excise tax under section 4701 in connection with the repeal of section 163(f)(2)(B)(the bearer debt repeal). Notice 2012-20 will be published in the Internal Revenue Bulletin 2012-13, dated March 26, 2012. Issuers of debt obligations that…
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Senate Accepts Levin Tax Havens Measure to Combat Offshore Tax Abuses

The Senate adopted an amendment to the surface transportation bill (S. 1813) by voice vote March 8 that would prohibit foreign financial institutions from having access to the U.S. financial system if they are found to be aiding tax evasion. Under Section 311 of the Patriot Act, Treasury can take a range of measures against…
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