Rocco Femia Quoted in BNA Daily Report for Executives Regarding International Tax Issues

"Government Still Looking at Asset Threshold Issue in Uncertain Tax Positions Proposal"
BNA Daily Report for Executives
05.19.10Rocco Femia comments on several international tax proposals during a panel sponsored by the DC Bar Association, including the House-passed Small Business and Infrastructure Jobs Tax Act, which contains a provision intended to limit treaty benefits for certain deductible payments to treaty eligible companies that are owned by companies in third countries that do not have a tax treaty with the United States. Femia noted the proposal has been heavily criticized as "an explicit override of all existing U.S. tax treaties" and stressed that merely because a country does not have a tax treaty with the United States, that does not mean a lack of taxation. Transactions often are structured through countries "that are not tax havens," he said.
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