News & Analysis as of

Foreign Corporations Proposed Regulation

Vinson & Elkins LLP

Treasury Releases Long-Awaited Proposed Regulations on the Corporate Alternative Minimum Tax

Vinson & Elkins LLP on

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Proskauer - Tax Talks

Proposed Regulations Issued on the Excise Tax on Repurchases of Corporate Stock

Proskauer - Tax Talks on

On April 9, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued two sets of proposed Treasury Regulations related to section 4501, REG-115710-22, which provides guidance on...more

Holland & Knight LLP

Treasury, IRS Issue Inbound Corporation Stock Repurchase Excise Tax Proposed Regulations

Holland & Knight LLP on

Following the release of initial guidance in the form Notice 2023-2, the U.S. Department of the Treasury (Treasury) and IRS issued proposed regulations (the Proposed Regulations) under the Section 4501 stock repurchase excise...more

A&O Shearman

Notice 2024-16 Announces Limited Guidance Under Section 961(c)

A&O Shearman on

On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the...more

Torres Trade Law, PLLC

CFIUS Updates: New FAQs Clarify Positions; Possible Expansion of Scope of Real Estate Review

Torres Trade Law, PLLC on

In our recent article Amid TikTok Tensions, CFIUS Signals Increased Enforcement and Other Updates, we discussed updates from the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”) primarily with...more

McDermott Will & Emery

IRS Releases Proposed Regulations Addressing Repatriations of Intangible Property

McDermott Will & Emery on

BACKGROUND: SECTION 367(D) Section 367(d) generally addresses outbound transfers of intangible property to a foreign corporation. It treats a US transferor that transfers intangible property subject to Section 367(d) as...more

Proskauer - Tax Talks

Proposed Regulations Issued for Repatriations of Intangible Property under Section 367(d)

Proskauer - Tax Talks on

On May 2, 2023, the Department of the Treasury and Internal Revenue Service (“IRS”) issued proposed Treasury Regulations (REG-124064-19) that would, in certain cases, terminate the application of Section 367(d) when...more

Fenwick & West LLP

Can you Prepay a Section 367(d) Royalty? IRS Says No (This Time)

Fenwick & West LLP on

Taxpayers with royalties owing from a foreign affiliate may wish to negotiate a prepayment of the future royalty stream for a lump sum price. This could include accelerating foreign source income or repatriating cash from a...more

Barnea Jaffa Lande & Co.

EU Proposes to Regulate Companies That Receive Foreign Governments Support – How Will This Affect Foreign and Israeli Companies?

On July 13, 2022, the European Parliament and the European Council agreed on a new regulation concerning “foreign subsidiaries that distort the European market.” Their agreement is the final stage prior to voting on the...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

Proskauer - Tax Talks on

On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

Bilzin Sumberg

Domestic and International Private Clients and their Closely Held Companies: Update on the Corporate Transparency Act

Bilzin Sumberg on

In a blog post early last year,  we reported on the passage of the Corporate Transparency Act (“CTA”) enacted on January 1, 2021, as part of the National Defense Authorization Act for Fiscal Year 2021. As previously...more

WilmerHale

China Tightens Control Over Overseas Securities Listings in Name of Data Security

WilmerHale on

On July 6, the General Office of the Central Committee of China’s Communist Party and the General Office of the State Council jointly issued the Opinions on Strictly Cracking Down on Illegal Securities-related Activity in...more

Holland & Knight LLP

Breaking the "Equity Wall": Proposed Regulations Limit Chances to Minimize U.S. Withholding Tax

Holland & Knight LLP on

The U.S. Department of the Treasury (Treasury) issued proposed regulations (the Proposed Regulations) on April 8, 2020, that would restrict foreign persons' ability to minimize U.S. tax through "conduit" financing...more

McDermott Will & Emery

Weekly IRS Roundup November 9 – November 13, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 9, 2020 – November 13, 2020... November 9, 2020: The IRS released Notice 2020-75...more

McDermott Will & Emery

Weekly IRS Roundup August 10 – August 14, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 10, 2020 – August 14, 2020... August 10, 2020: The IRS published corrections to a notice...more

Bracewell LLP

Straight from the Source: Proposed Regulations Seek to Implement TCJA Changes to Source of Income Rules, Altering Treatment for...

Bracewell LLP on

The source of income is a critical component of U.S. tax rules for both U.S. taxpayers operating internationally (namely, with respect to foreign tax credit planning) and foreign persons with investment or other activity in...more

Fenwick & West LLP

PFIC: What U.S. Investment Funds Should be Particularly Aware of and Newly Proposed Regulations

Fenwick & West LLP on

U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules, which could substantially increase the tax owed on exit for U.S....more

Proskauer - Tax Talks

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

Proskauer - Tax Talks on

On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more

Alston & Bird

Down the Rabbit Hole: Guidance Addressing Downward Attribution After Repeal of Section 958(b)(4)

Alston & Bird on

The IRS released Proposed Regulations and a Revenue Procedure addressing the Tax Cuts and Jobs Act’s repeal of Section 958(b)(4). Our International Tax Group explores how this guidance affects numerous provisions of the Code....more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

A&O Shearman

Guidance on CFC ‘Downward Attribution Rules’ Provides Limited Relief to US Taxpayers

A&O Shearman on

On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more

McDermott Will & Emery

Weekly IRS Roundup August 19 – 23, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 19 – 23, 2019. August 20, 2019: The IRS released a proposed regulation that provides...more

Dechert LLP

IRS Releases Proposed Tax Regulations on PFICs, Including Guidance for Foreign Insurance Corporations and Their Investors

Dechert LLP on

The U.S. Department of the Treasury and the Internal Revenue Service on July 10, 2019, released proposed regulations relating to the tax treatment of investors that own stock of a passive foreign investment company (“PFIC”)...more

Proskauer - Tax Talks

Proposed Regulations Provide Clarity for Qualified Foreign Pension Fund Exception

Proskauer - Tax Talks on

On June 7, 2019, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) released proposed Treasury regulations under Sections 897, 1445 and 1446 (the “Proposed Regulations”) regarding the exception...more

Jones Day

Warning: U.S. Tax Regulations Impact Completed Foreign Sales Retroactively and Domestic Partnerships

Jones Day on

The Situation: On June 14, 2019, the IRS and U.S. Treasury released more than 500 pages of proposed, temporary, and final regulations addressing the taxation of U.S.-controlled foreign corporations. The Development:...more

47 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide