On Oct. 1, the Internal Revenue Service (the Service) issued Revenue Procedure 2019-40 (the Revenue Procedure), which offers guidance relating to ownership by certain U.S. persons of stock in “controlled foreign corporations”...more
On May 23, the Department of the Treasury and the IRS published final regulations (the final regulations) under Section 956 of the Internal Revenue Code of 1986, as amended (the Code). ...more
Background On Oct. 31, 2018, the Internal Revenue Service issued proposed regulations under Section 956 of the Internal Revenue Code that will eliminate the adverse tax consequences when a U.S. parent corporation (i)...more
11/16/2018
/ Collateral ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Foreign Subsidiaries ,
Internal Revenue Code (IRC) ,
IRS ,
Lenders ,
Parent Corporation ,
Proposed Regulation ,
Section 956 ,
Tax Deductions ,
Tax Planning ,
Voting Securities
The recently enacted tax reform act (the Act) significantly altered the U.S. taxation of foreign income. Perhaps most prominently, the Act allows U.S. corporations to fully deduct (and thus not pay tax on) dividends received...more
3/29/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration