The proposed modifications would create opportunities for enhanced CFC credit support.
On October 31, 2018, the US Treasury Department and the Internal Revenue Service (IRS) released proposed Treasury Regulations (the...more
Notice 2018-13 details the government’s intent to issue regulations addressing additional Section 965 computational issues. The new regulations will clarify, among other things, that US shareholders will be permitted to elect...more
US Tax Court decision may facilitate tax-efficient investment structures for non-US investors investing in US operating partnerships, directly or through investment funds....more
The principal effect of the rules would be to turn virtually any contribution of appreciated property by a US person to a section 721(c) partnership into a taxable gain recognition event.
On August 6, the US Treasury...more
The IRS notice further eases, but does not delay, FATCA implementation.
On May 2, the Internal Revenue Service (IRS) published Notice 2014-33 (the Notice), which announced that calendar years 2014 and 2015 will be...more
Foreign financial institutions, such as offshore funds, should register with the IRS by May 5 and review new and revised IRS forms.
The July 1 start date for Foreign Account Tax Compliance Act (FATCA) withholding on...more
IRS modifies rules allowing the deferral method of accounting for advance payments received for the sale of gift cards that are redeemable by an unrelated party.
On July 24, the Internal Revenue Service (IRS) released an...more
IRS notice postpones FATCA withholding by six months and revises other key deadlines.
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