Latest Publications

Share:

Doubling up: Proposed regulations address interaction of dual consolidated loss rules and GloBE Model Rules, disregarded payment...

Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed...more

Proposed regulations reduce flexibility of foreign currency mark-to-market election

On August 19, 2024, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (Proposed Regulations) making changes to previously proposed regulations published in December...more

Doing less with Moore: Supreme Court upholds section 965 transition tax in Moore v. United States

Almost exactly a year after it shook the tax world by granting certiorari, on June 20, 2024, the Supreme Court issued its opinion in Moore v. United States, No. 22-800. By a vote of 7-2, the Court upheld the constitutionality...more

IRS Notice previews proposed regulations addressing PTEP basis of acquired CFCs

On December 29, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published Notice 2024-16 (Notice) announcing their intent to issue proposed regulations relating to the determination of...more

On notice: IRS and Treasury preview guidance related to Pillar Two taxes and extend foreign tax credit relief

The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more

Five things to know about the Supreme Court’s grant of certiorari in Moore v. United States

The Supreme Court granted certiorari on June 26 with respect to the Ninth Circuit’s decision in Moore v. United States. The question presented is whether the section 965 transition tax is a “direct tax” that violates the...more

An incomplete picture: Democratic senators release “framework” for international tax overhaul

On August 25, 2021, Senate Finance Committee members Wyden, Brown, and Warner released draft bill language and a section-by-section summary of their proposed International Tax Reform Framework. The legislative language is...more

Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure: ..Allows controlled...more

High time: Final and proposed regulations rework high-tax rule for GILTI and subpart F

Recently released final regulations provide some relief to taxpayers that are subject to high foreign taxes on their global intangible low-taxed income (GILTI), but whether the GILTI high-tax exclusion is beneficial to any...more

Second time’s the charm? New proposed section 163(j) regulations treat electing CFC groups as a single corporation and eliminate...

Significant provisions of the 2020 Proposed Regulations addressing the application of section 163(j) to foreign corporations and their shareholders include: ..An election under which a controlled foreign corporation (CFC)...more

IRS issues final (for now) debt/equity regulations

Final regulations addressing the treatment of certain related-party indebtedness as equity for US federal income tax purposes were released on May 13, 2020. The regulations finalize without material change regulations that...more

Surprise! Section 901(m) final regulations

Surprisingly, in the midst of the COVID-19 emergency, final regulations under Section 901(m) were published. While important for M&A transactions, Section 901(m) had largely been treated as an afterthought in light of the...more

Changing the BEAT - Final regulations answer key questions, proposed regulations give new relief

A year after the initial proposed BEAT regulations were released, Treasury and the IRS have issued a package of final and proposed regulations under § 59A of the Internal Revenue Code of 1986, as amended (the Code), the...more

Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)

The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more

Relief for REMICs addressing phaseout of LIBOR

New proposed regulations provide guidelines for alterations to certain interests in real estate mortgage investment conduits (REMICs) and loans held by REMICs to take into account the anticipated phaseout of LIBOR, the...more

Fine-tuning the course - Final Regulations enhance symmetry between taxation of actual dividends and section 956 inclusions

On May 23, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (TD 9859) (the Final Regulations) modifying the application of section 956 of the Internal Revenue...more

Treasury and the IRS address classification and ordering rules for previously taxed earnings and profits of foreign corporations

On December 14, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued guidance (Notice 2019-01 or the Notice) describing proposed regulations that they intend to issue addressing...more

And the BEAT goes on – proposed regulations clarify the application of the base-erosion and anti-abuse tax

On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations under section 59A of the Internal Revenue Code of 1986, as amended, commonly referred to as...more

Allocation, apportionment and attribution, oh my – Proposed foreign tax credit regulations provide critical guidance

On November 28, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations concerning foreign tax credit determinations and related issues (Proposed Regulations) to take...more

INXS? IRS issues proposed regulations under section 163(j)

On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue Code of 1986, as amended...more

Deemed participation better than no participation? Proposed regulations expand tax-free treatment to section 956 inclusions of...

On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of the Internal Revenue Code of...more

GILTI by consolidation

Public Law 115-97 (the Tax Cuts and Jobs Act (TCJA)) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. On September 13, 2018, the Department of the Treasury...more

In transition—proposed section 965 regulations incorporate and expand on prior guidance

On August 1, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations, which were published in the Federal Register on August 9, 2018 (Proposed Regulations),...more

Ireland after US Tax Reform - What does it mean for business?

Ireland has an open, pro-business economy that offers significant opportunities to multinational companies, including as a gateway into the European market for US multinationals across all business sectors. Ireland remains...more

No rest for the weary - final regulations continue to target inversions without major changes

INTRODUCTION - On July 11, 2018, Treasury and the Internal Revenue Service (IRS) published final inversion regulations (TD 9834) which are largely consistent with the temporary (T.D. 9761) and proposed regulations...more

39 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide