DC Bar Taxation Section and International Tax Committee Luncheon Program
Rocco Femia will speak on "Recent and Looming Legislation Affecting International Tax."
Topics to be covered include the codification of the economic substance doctrine, application of withholding to certain equity swaps, the anti-treaty-shopping proposals, the foreign tax credit separation proposal, and the potential repeal of the 80/20 company rules. The panel also will discuss the international tax implications of the proposal to require reporting of uncertain tax positions to the IRS.
Topics to be covered include the codification of the economic substance doctrine, application of withholding to certain equity swaps, the anti-treaty-shopping proposals, the foreign tax credit separation proposal, and the potential repeal of the 80/20 company rules. The panel also will discuss the international tax implications of the proposal to require reporting of uncertain tax positions to the IRS.