News & Analysis as of

CFC Section 956

Proskauer - Tax Talks

The Senate Finance Committee’s proposal for tax reform, and how it compares with the bill passed by the House Committee on Ways &...

Proskauer - Tax Talks on

UPDATE: The Senate Finance Committee last night released a revised version of the Chairman’s Mark of the Tax Cuts and Jobs Act. We are reviewing these changes and will release an update soon... On Thursday, November 9, the...more

Goulston & Storrs PC

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

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

Fenwick & West LLP

Tax Alert: New Chief Counsel Memorandum Revisits Definition of “Obligation” under IRC Section 956

Fenwick & West LLP on

ILM 201436047 - In a recent memorandum, ILM 201436047 (Sept. 8, 2014), the IRS chief counsel seemingly exceeded the scope of its own regulations in advising that the amount of a CFC’s section 956 investment included...more

Mintz

IRS Chief Counsel Shrugs Off Taxpayer’s Section 956 Gambit

Mintz on

In a recently released Chief Counsel Advice Memorandum (the “Memorandum”), the IRS Office of Chief Counsel (International) addressed an interesting and somewhat creative internal financing structure deployed by a taxpayer...more

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