Section 956

News & Analysis as of

Treasury and IRS Issue New Temporary Treasury Regulations

On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued new temporary Treasury regulations addressing the application of Internal Revenue Code Section 956 to certain...more

Further Crackdown on Offshore Corporations

In their continued effort to crackdown on offshore activity, the IRS and Treasury released proposed regulations yesterday that target debt held by foreign partnerships. These regulations provide that debt held by foreign...more

New IRS Guidance Expands Application of Section 956 to Controlled Foreign Corporations that Own Partnerships

Earlier this week the IRS published two sets of regulations addressing when a US owner of a Controlled Foreign Corporation (CFC) has a deemed repatriation through the use of a CFC-owned foreign partnership. The regulations...more

Morrison & Foerster Quarterly News Tax Talk - Volume 7, No.4 January 2015

In This Issue: - Congress Passes Year-End Tax Extenders Bill - House Adopts New “Dynamic Scoring” Rule - Foreign Fund Engaged in Lending and Stock Distribution Not Protected by “Trading in Stock or Securities”...more

United States Property Investments under Section 956 of the Code

I. Background and Overall Scope of Section 956 - The overall purpose of section 956 is to tax investments made by CFCs in specified categories of “United States property” on a constructive dividend basis. The...more

Tax Alert: New Chief Counsel Memorandum Revisits Definition of “Obligation” under IRC Section 956

ILM 201436047 - In a recent memorandum, ILM 201436047 (Sept. 8, 2014), the IRS chief counsel seemingly exceeded the scope of its own regulations in advising that the amount of a CFC’s section 956 investment included...more

IRS Taking Closer Look at Section 956 Inclusions

Each “U.S. Shareholder” of a controlled foreign corporation (“CFC”) is required to include in their gross income as a deemed distribution their pro rata share of the amount determined under section 956 for that year (i.e.,...more

Tax Talk -- Volume 7, No. 2 -- July 2014

In This Issue: - As FATCA Begins, IRS Rolls out Withholding Forms, Increases IGA Count - IRS Issues Final Circular 230 Rules Simplifying Written Tax Advice Requirements - Mortgage CCA Raises More...more

IRS Chief Counsel Shrugs Off Taxpayer’s Section 956 Gambit

In a recently released Chief Counsel Advice Memorandum (the “Memorandum”), the IRS Office of Chief Counsel (International) addressed an interesting and somewhat creative internal financing structure deployed by a taxpayer...more

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