Is your inventory sales income U.S. or foreign source? Well, it depends. Our International Tax Group explores the various sourcing rules the IRS has proposed to sort out possible inconsistencies and overlaps caused by the Tax...more
In long-awaited guidance on Section 163(j) post-tax reform, the Treasury and IRS present taxpayers with an expansive definition of “interest,” subjective anti-abuse rules, complex computational instructions, and several...more
On October 13, the Treasury released highly anticipated final and temporary regulations (T.D. 9790) under Section 385,
which authorizes the Treasury to devise regulations to determine when an interest in a corporation is...more
Generally, a disregarded entity is not subject to U.S. tax or information reporting, so the IRS is limited to gleaning information from tax filings by an entity’s owner. But foreign owners of disregarded entities often do not...more
In late September, the IRS issued final regulations describing six requirements for a transaction or series of transactions to qualify as a reorganization under Section 368(a)(1)(F) (an “F reorganization”). The IRS...more