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
The Treasury Department (Treasury) and the Internal Revenue Service (Service) recently issued proposed regulations that, if finalized as proposed, could have a significantly adverse effect on the ability of a regulated...more
The recently proposed regulations, if finalized, would govern the treatment of RICs’ income inclusions in respect of CFCs and PFICs for purposes of the income test applicable to RICs; in related guidance, the IRS also...more