Daily Tax Update - March 13, 2006

IRS ISSUES FINAL REGULATIONS REVISING WITHHOLDING, REPORTING RULES ON PAYMENTS TO FOREIGN PERSONS:
Today, the IRS issued final regulations (T.D. 9253) that revise existing rules on the withholding of income tax on U.S.-source income paid to foreign persons and related rules on the collection, deposit, refund, and credits of withheld amounts.

  • The final regulations adopt the proposed regulations (REG-125443-01) with two modifications. The final regulations further ease the taxpayer identification number requirement for some foreign grantor trusts and provide new rules on the reporting of treaty-based return positions under section 6114.
  • For additional information, contact Philip R. West via e-mail.

PENSION BILL CONFEREES SCHEDULED TO MEET THIS WEEK:
House and Senate conferees to the pension reform bill are scheduled to meet later this week to begin reconciling the differences between the House and Senate-passed bills. The conferees are hopeful to complete work by March 31 and complete final passage of a conference report by April 7.

  • A comparison of the House and Senate pension bills can be accessed here.   

JOINT COMMITTEE ON TAXATION RELEASES DESCRIPTION OF REVENUE PROVISIONS IN FISCAL YEAR 2007 BUDGET:
Today, the Joint Committee on Taxation released a summary of the revenue provisions in the President’s Fiscal Year 2007 budget.

  • The document can be accessed here

INTERNAL REVENUE SERVICE - CIRCULAR 230 DISCLOSURE:
As provided for in Treasury regulations, advice (if any) relating to federal taxes that is contained in this communication (including attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any plan or arrangement addressed herein.

STEPTOE & JOHNSON LLP - TAX PRACTICE
Steptoe & Johnson LLP has one of the largest and most diverse law firm tax practices in the country. The practice covers the entire spectrum of federal taxation, including representation of businesses before the Congress, Treasury and the national office of the IRS; transactional planning for domestic and multinational corporations; complex audit and controversy work for corporations and other business interests contesting IRS adjustments; litigation before the Tax Court, Court of Federal Claims, district courts, courts of appeals and the Supreme Court. The firm's tax practice also encompasses all aspects of employee benefits (ERISA), executive compensation, tax-exempt organizations and charitable giving.  Steptoe has an extensive state and local tax practice, representing an array of business clients on complex sales and use tax, corporate income tax and property tax matters, both advising those clients and handling audits, administrative appeals, and litigation for them.  Read  more information on Steptoe's tax practice