Daniel Nelson

Daniel Nelson

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Final Section 956 Regulations Follow Approach of Proposed Regulations—with Two Helpful Modifications

Final regulations applicable to controlled foreign corporations and their US shareholders, issued by the US Treasury under Code Section 956, generally follow previously proposed regulations but introduce two modifications: a...more

6/17/2019  /  Banking Sector , Controlled Foreign Corporations , Financial Services Industry , Section 956 , Shareholders , U.S. Treasury

Proposed Regulations Would Modify the Application of Section 956 to Many Financing Transactions

The proposed modifications would create opportunities for enhanced CFC credit support. On October 31, 2018, the US Treasury Department and the Internal Revenue Service (IRS) released proposed Treasury Regulations (the...more

11/9/2018  /  Controlled Foreign Corporations , IRS , Section 956 , U.S. Treasury
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