The Situation: On June 14, 2019, the IRS and U.S. Treasury released more than 500 pages of proposed, temporary, and final regulations addressing the taxation of U.S.-controlled foreign corporations.
The Development:...more
6/25/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Tax ,
GILTI tax ,
IRS ,
Multinationals ,
New Rules ,
Partnerships ,
Proposed Regulation ,
Retroactive Taxes ,
Stocks ,
U.S. Treasury
On November 26, 2018, the U.S. Treasury released proposed regulations under section 163(j) of the Internal Revenue Code, which, as amended by last year's tax reform, generally limits deductibility of net business interest...more
The proposed regulations, released October 31, 2018, generally provide tax-free treatment to a U.S. corporate parent of a controlled foreign corporate subsidiary ("CFC") for deemed dividends triggered when the CFC provides...more
11/2/2018
/ Borrowers ,
Controlled Foreign Corporations ,
Joint and Several Liability ,
Lenders ,
Parent Corporation ,
Proposed Regulation ,
Real Estate Investments ,
Section 956 ,
Shareholders ,
Subsidiaries ,
U.S. Treasury
The Situation: On November 2, 2017, the House Ways and Means Committee released its first draft of much-anticipated comprehensive U.S. tax reform legislation as the "Tax Cuts and Jobs Act." Chairman Brady’s markup of the bill...more
11/7/2017
/ Acquisitions ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Death Tax ,
EBITDA ,
Excise Tax ,
Executive Compensation ,
Foreign Corporations ,
Foreign Earned Income ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Itemized Deductions ,
MACRS ,
Mortgage Interest ,
Net Operating Losses ,
Partnerships ,
Pass-Through Entities ,
Principal Executive Officer ,
Proposed Legislation ,
REIT ,
Section 409A ,
Shareholders ,
Subpart F ,
Tax Credits ,
Tax Deductions ,
Tax Reform ,
Transfer Taxes ,
Trump Administration ,
Ways and Means Committee