Tweaking Tax On Foreign Investments In The US

Law360, New York (December 15, 2011, 2:51 PM ET) -- On Nov. 2, 2011, the Internal Revenue Service issued long-awaited guidance concerning the taxation of certain income of foreign governments from investments in the United States under Section 892 of the Internal Revenue Code. This guidance takes the form of proposed regulations that modify and expand existing temporary regulations issued in 1988. The 1988 temporary regulations were widely criticized as unduly restrictive. Ultimately the criticisms culminated in the issuance of these proposed regulations.

Given the significantly increased investing activities of foreign governments (including sovereign wealth funds)...
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