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Proposed Regulations Would Modify the Application of Section 956 to Many Financing Transactions

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

IRS, Treasury Issue Guidance on Section 965 Deemed Repatriation Rules, Signal Important Form 5471 Exception

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

Grecian Magnesite Mining: Impact on Investments by Non-US Investors in US Funds

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

Treasury and IRS Release Notice 2015-54: Potential Impact on Domestic and Foreign Partnerships

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

IRS Announces Transitional Period for FATCA Enforcement, Other FATCA Rule Changes

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

Initial FATCA Registration/Withholding Dates Draw Near

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

4/11/2014  /  FATCA , FATCA Timeline , FFI , IRS

New Accounting Rules for Gift Cards Redeemable by Unrelated Entities

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

Treasury Revises FATCA Implementation Timeline

IRS notice postpones FATCA withholding by six months and revises other key deadlines. ...more

7/16/2013  /  Delays , FATCA , FFI , Foreign Banks , IGAs , IRS , Tax Reform , U.S. Treasury
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