Jose Rego

A&O Shearman

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Treasury and the IRS proposed regulations on previously taxed earnings and profits

On November 29, 2024, the U.S. Treasury Department and IRS released long-awaited proposed regulations (REG-105479-18) under sections 959 and 961, and certain other provisions of the Internal Revenue Code of 1986, as amended...more

12/4/2024 / Business Profits , Corporate Governance , Earnings Reports , Foreign Earned Income , Internal Revenue Code (IRC) , IRS , Proposed Regulation , Proposed Rules , U.S. Treasury

Proposed dual consolidated loss regulations would disallow U.S. tax use of foreign losses viewed as reducing Pillar Two tax...

On August 6, 2024, the U.S. Treasury Department (“Treasury”) issued proposed regulations under section 1503 (the “Proposed Regulations”) that address the interaction between the dual consolidated loss (“DCL”) rules and the...more

8/13/2024 / Acquisitions , Corporate Governance , Mergers , Pillar 2 , Proposed Regulation , Tax Rates , U.S. Treasury

Notice 2024-16 Announces Limited Guidance Under Section 961(c)

On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the...more

1/8/2024 / Corporate Taxes , Double Taxation , Federal Taxes , Foreign Corporations , International Tax Issues , IRS , Proposed Regulation , U.S. Treasury

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