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U.S. Treasury Ordinary Business Exception

McDermott Will & Emery

New Temporary Regulations Narrow the Application of the Subpart F Active Rents and Royalties Exception

McDermott Will & Emery on

On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Temporary Regulation § 1.954-2T concluding that third party arrangements cannot be taken into account for...more

Skadden, Arps, Slate, Meagher & Flom LLP

"New Regulations Address Outbound Transfers and Transfer Pricing"

On September 14, 2015, the Internal Revenue Service (the IRS) and Treasury Department proposed new regulations addressing the tax treatment under Section 367 of the Internal Revenue Code (the Code) of certain transfers by...more

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