Final regulations applicable to controlled foreign corporations and their US shareholders, issued by the US Treasury under Code Section 956, generally follow previously proposed regulations but introduce two modifications: a...more
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
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 notice postpones FATCA withholding by six months and revises other key deadlines.
...more