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Safe Harbors Foreign Corporations

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

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

Jones Day

Jones Day Talks: Navigating Foreign Direct Investment in Germany

Jones Day on

Germany has two different sets of rules for the review of foreign direct investments. The relevant ordinance, the Außenwirtschaftsverordnung, or AWV, provides for a sector-specific review process applying to the acquisition,...more

Latham & Watkins LLP

New Final Inversion Rules Maintain Tight Standard for Corporate Expatriations

Latham & Watkins LLP on

For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules. On June 3, 2015, the US Department of the...more

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