Michael Miles

Michael Miles

Eversheds Sutherland (US) LLP

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Reversing Course—Proposed Regulations Reverse IRS Ruling Position on Treatment of Income from CFCs and PFICs for RIC Qualification...

On September 27, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (REG-123600-16) (the Proposed Regulations) under section 851 addressing the income test applicable...more

10/4/2016  /  Business Development Companies , Commodities , Controlled Foreign Corporations , IRS , Passive Foreign Investment Company , Proposed Regulation , Regulatory History , Revenue Procedure 2016-50 , U.S. Treasury
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