Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations -
Introduction:
On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more
10/5/2015
/ Administrative Procedure Act ,
Amended Regulation ,
BEPS ,
Clawbacks ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Cost-Sharing ,
Foreign Corporations ,
Goodwill ,
Intangible Property ,
IRC Section 367 ,
IRS ,
Partnerships ,
Proposed Regulation ,
Section 482 ,
Stock-Based Compensation ,
Tax Court ,
Tax Reform ,
Transfer Pricing ,
Transfers ,
U.S. Treasury
On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Temporary Regulation § 1.954-2T concluding that third party arrangements cannot be taken into account for...more
9/25/2015
/ Controlled Foreign Corporations ,
Corporate Officers ,
Cost-Sharing ,
Employees ,
IRS ,
New Regulations ,
Ordinary Business Exception ,
Rent ,
Royalties ,
Safe Harbors ,
Subpart F ,
Third-Party ,
U.S. Treasury
On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued new temporary Treasury regulations addressing the application of Internal Revenue Code Section 956 to certain...more
9/22/2015
/ Anti-Abuse Rule ,
Anti-Avoidance ,
Controlled Foreign Corporations ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Partnerships ,
Section 956 ,
Shareholders ,
Tax Avoidance ,
U.S. Treasury