Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC...more
5/31/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Distribution Rules ,
Final Rules ,
Financial Guarantee Requirements ,
IRS ,
Multinationals ,
New Regulations ,
Section 956 ,
Stocks ,
Tax Cuts and Jobs Act ,
Voting Shares
On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more
4/23/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
Tax Reform
On August 21, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-67 (the “Notice”), addressing issues relevant to tax-exempt organizations arising under new Section 512(a)(6) of the Internal Revenue Code (the...more
9/5/2018
/ Controlled Foreign Corporations ,
GILTI tax ,
Income Taxes ,
IRS ,
NAICS ,
Partnerships ,
Public Comment ,
Reporting Requirements ,
Tax Exempt Entities ,
Tax Exemptions ,
UBTI