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
Background - The Internal Revenue Service (IRS) introduced Schedules K-2 and K-3 beginning with tax year 2021. Schedule K-2 (Partners’ Distributive Share Items−International) and Schedule K-3 (Partner’s Share of Income,...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 8, 2022...more
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
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
IRS announces the issuance of new regulations that will provide relief for certain regulated investment companies that receive foreign tax refunds by either netting the refund against foreign taxes paid in the year of the...more
NUMBER OF THE WEEK: 52 percent. The likelihood that tax reform will happen in 2017 or earlier, according to the tax experts that participated in the Tax Council (TTC) and Ernst & Young (EY) Tax Reform Business Barometer in...more
At the end of the 2013, the IRS issued, in the form of a Chief Counsel Advice [1] (CCA 201349015), its view on the applicability of transfer pricing concepts to transactions involving disregarded entities (“DEs”) in the...more