News & Analysis as of

Foreign Corporations Related Parties

Troutman Pepper

Testing 'Related Party' Acquisitions for 338 Election Eligibility - Tax Update Volume 2019, Issue 1

Troutman Pepper on

When a taxpayer is considering purchasing a foreign corporation, tax planning must be part of the process in order to mitigate unwanted tax consequences. For example, an election under section 338(g) of the Code has been a...more

BakerHostetler

Final and Temporary Debt-Equity Regulations Under Section 385 Implement Highly Favorable Changes

BakerHostetler on

On Oct. 13, 2016, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final and temporary regulations under Section 385 governing the treatment of certain instruments as debt or equity...more

Latham & Watkins LLP

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

Latham & Watkins LLP on

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

Latham & Watkins LLP

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Latham & Watkins LLP on

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

4 Results
 / 
View per page
Page: of 1

"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