Volatile trading markets and economic instability may prompt taxpayers to modify, purchase, or repurchase debt; participants should consider the tax consequences.
Key Points:
..Issuers may incur immediate income in the...more
Section 956 final regulations confirm those eligible for territorial dividend exemption can benefit from foreign guarantee and collateral support without incurring US tax.
On May 23, 2019, the US Treasury and Internal...more
But Holding Period and Other Requirements Add Complexity -
On October 31, 2018, the US Treasury and Internal Revenue Service issued proposed regulations (the Proposed Regulations) that would eliminate, in most...more
New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions.
On April 4, 2016, the US Department of the Treasury (Treasury) and...more
4/21/2016
/ Acquisitions ,
Anti-Inversion Regulations ,
Controlled Foreign Corporations ,
Controlled Groups ,
Corporate Taxes ,
De Minimus Quantity Exemption ,
Dividends ,
Foreign Corporations ,
Inversion ,
IRS ,
Multinationals ,
Proposed Regulation ,
Related Parties ,
Stocks ,
U.S. Treasury
Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt.
On April 4, 2016, the US Department of the Treasury (Treasury) and the...more
4/21/2016
/ Affiliates ,
Anti-Avoidance ,
Consolidated Tax Returns ,
Controlled Groups ,
Cross-Border Transactions ,
Debt ,
Dividends ,
Foreign Corporations ,
Income Taxes ,
IRS ,
Proposed Regulation ,
REIT ,
Related Parties ,
Required Documentation ,
Stocks ,
U.S. Treasury ,
Withholding Tax