The final regulations addressing the GILTI high-tax exception retain the general approach of the proposed regulations with some simplifying changes.
Key Points:
..Taxpayers can elect on an annual basis whether to...more
The proposed regulations provide rules for identifying which taxpayers are subject to the BEAT and for computing BEAT liability.
Key Points:
The base erosion and anti-abuse tax (BEAT) proposed...more
Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct.
On August 6, 2018, the US Tax Court decided...more
New regulations more notable for what they retain than what they change.
Key Points:
..The US anti-inversion rules have more than a 15-year history of impacting the structure and practicality of certain cross-border...more
Anti-avoidance rules and limitations on application of the stock attribution rules among the topics to be addressed in forthcoming regulations.
Key Points -
..Certain transactions intended to reduce transition tax...more
Tax reform plans would fundamentally alter the landscape for key business decisions, impacting a business’ legal, finance, corporate development and other divisions, as well as tax groups.
Key Points:
..Tax reform...more
Regulations provide rules for determining MLP qualifying income from certain mineral or natural resource-related activities and services.
On January 19, 2017, the US Department of the Treasury (Treasury) and the Internal...more
Seeking to curb “excessive” use of related-party debt, Treasury and IRS retain basic framework, but significantly narrow the scope, of the Proposed Regulations.
On October 13, 2016, the US Department of the Treasury...more
Action prompted by concerns that settlements of EU State Aid tax investigations may result in inappropriate foreign tax credit splitter structures.
On September 15, 2016, the US Internal Revenue Service (the IRS) issued...more
New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions.
On April 4, 2016, the US Department of the Treasury (Treasury) and...more
4/21/2016
/ Acquisitions ,
Anti-Inversion Regulations ,
Controlled Foreign Corporations ,
Controlled Groups ,
Corporate Taxes ,
De Minimus Quantity Exemption ,
Dividends ,
Foreign Corporations ,
Inversion ,
IRS ,
Multinationals ,
Proposed Regulation ,
Related Parties ,
Stocks ,
U.S. Treasury
Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt.
On April 4, 2016, the US Department of the Treasury (Treasury) and the...more
4/21/2016
/ Affiliates ,
Anti-Avoidance ,
Consolidated Tax Returns ,
Controlled Groups ,
Cross-Border Transactions ,
Debt ,
Dividends ,
Foreign Corporations ,
Income Taxes ,
IRS ,
Proposed Regulation ,
REIT ,
Related Parties ,
Required Documentation ,
Stocks ,
U.S. Treasury ,
Withholding Tax
Tax partnerships, including MLPs, seeking to restructure debt face peril and possibility during challenging times.
With the lowest oil prices in more than a decade and the equity markets effectively closed to them, oil...more
IRS’ proposed MLP regulations generate flurry of specific industry-related comments and spur public hearing.
“I’m mad as Hell, and, frankly, I’m not going to take it anymore.”
— Paraphrase of concerned citizen and...more
10/9/2015
/ Commodities ,
Energy Sector ,
Exploration and Production Assets ,
IRS ,
Liquid Natural Gas ,
Marketing ,
Master Limited Partnerships ,
Mineral Exploration ,
Mineral Leases ,
Minerals ,
Oil & Gas ,
Passive Activity ,
Pipelines ,
Private Letter Rulings ,
Qualifying Income ,
Surface Transportation ,
U.S. Treasury ,
Underground Injection Wells
Proposed regulations seek to provide rules for determining MLP qualifying income from certain activities and services performed with respect to minerals or natural resources.
On May 5, 2015, the Internal Revenue...more