News & Analysis as of

Anti-Abuse Rule

New Temporary and Proposed Regulations Regarding Debt Allocations for Partnerships - 'Oh My' - Tax Update Volume 2017, Issue 1

by Pepper Hamilton LLP on

Although There Are Aspects of the Regulations that Practitioners and Taxpayers Still Disagree With, There Are Others that Are an Improvement on What Was Proposed Earlier. From 2013 through 2014, the IRS and the U.S....more

New Regulations Issued Regarding CFCs and Investment in U.S. Property

by Charles (Chuck) Rubin on

Income earned abroad by U.S. controlled foreign corporations can often qualify for deferral of U.S. income tax. If the foreign corporation is a controlled foreign corporation (CFC), its U.S. shareholders may be taxable on...more

IRS Publishes New Management Contract Safe Harbors for Property Financed with Tax-Exempt Bonds

by Foley & Lardner LLP on

On August 22, 2016, the Internal Revenue Service (IRS) released Rev. Proc. 2016-44, which provides new guidance on the treatment of “management contracts” for purposes of the restrictions on use of property financed with...more

IRS Proposes Modifications to Proposed Income Inclusion Regulations under Section 409A

by Proskauer - Tax Talks on

In general, proposed rulemaking issued in December 2008 with respect to income inclusion under Section 409A of the Internal Revenue Code of 1986, as amended (available here) provides that if there is a Section 409A violation...more

IRS Releases Proposed Regulations To Clarify Section 409A Provisions

by Proskauer - Tax Talks on

The Internal Revenue Service (IRS) recently issued proposed Treasury Regulations that would clarify certain provisions of the final regulations under Section 409A of the Internal Revenue Code of 1986, as amended (the “Code”)....more

International Tax Advisory: New Temporary Regulations Continue the Fight Against Inversions

by Alston & Bird on

On April 4, the Treasury released temporary regulations to attack (and prevent) inversions. Aimed at transactions designed to avoid the purposes of Sections 7874 and 367 and certain post-inversion avoidance transactions, the...more

New 871(m) Regulations Finalize Dividend Equivalent Payment Withholding Rules for Equity Derivatives

On September 17, 2015, the IRS and the Treasury Department issued final, temporary, and proposed regulations under section 871(m) of the Internal Revenue Code (collectively, the “new regulations”) that provide the rules for...more

Treasury and IRS Issue New Temporary Treasury Regulations

by McDermott Will & Emery on

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

New IRS Guidance Expands Application of Section 956 to Controlled Foreign Corporations that Own Partnerships

by Goulston & Storrs PC on

Earlier this week the IRS published two sets of regulations addressing when a US owner of a Controlled Foreign Corporation (CFC) has a deemed repatriation through the use of a CFC-owned foreign partnership. The regulations...more

Foundations in Fraud and Abuse: Building Blocks of Health Law

by Baker Donelson on

The Ober|Kaler Health Care General Counsel Institute is pleased to introduce its Foundations series, a collection of programs designed to equip in-house counsel with a solid foundation in the cornerstones of health law. The...more

Financial Services Tax – UK Update from Dechert’s Tax Group - February 2013: Get Ready for the GAAR

by Dechert LLP on

Draft clauses to introduce a new general anti-abuse rule (GAAR) into the UK tax code were published as part of the Finance Bill 2013 on 11 December 2012. Some form of general anti avoidance rule was first seriously canvassed...more

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