News & Analysis as of

U.S. Treasury Taxable Distributions

ArentFox Schiff

IRS, Treasury Release Proposed Regulations on Donor-Advised Funds

ArentFox Schiff on

The US Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) recently published proposed regulations under Section 4966 to provide additional guidance on several issues related to creating and...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

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

Proskauer - Tax Talks

IRS Proposed Regulations Under Section 305(c)

Proskauer - Tax Talks on

In April, the IRS issued proposed regulations interpreting deemed distributions under Section 305(c). Specifically, the proposed regulations would clarify the amount and timing of deemed distributions that result from an...more

Bryan Cave Leighton Paisner

Treasury Green Book Proposals — Inheriting IRAs

The Department of the Treasury has released the Treasury Green Book for Fiscal Year 2017, which provides explanations of the President’s budget proposals. One such proposal (remember…these are just proposals, not actual...more

Alston & Bird

Qualification of Certain Section 355 Spinoff Transactions Added to No-Rule List as IRS and Treasury Study the Topic

Alston & Bird on

On September 14, 2015, the government released Notice 2015-59 and Rev. Proc. 2015-43, both relating to Section 355 spinoffs. They respond to government concerns about spinoff transactions that result in the distributing...more

Morgan Lewis

IRS Issues Proposed Regulations Addressing “Fee Waiver” Arrangements

Morgan Lewis on

The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more

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