On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit regulations (the “2020 Final Regulations”) that include the allocation and...more
10/21/2020
/ Allocation of Funds ,
Apportionment ,
CFC ,
Foreign Tax Credits ,
GILTI tax ,
IRS ,
New Regulations ,
Popular ,
Proposed Regulation ,
Research and Development ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On September 1, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released final regulations on the base erosion and anti-abuse tax (the BEAT) under section 59A. These regulations finalize...more
The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more
1/29/2020
/ Capital Gains ,
Community Development ,
Economic Development ,
Estate Planning ,
Final Rules ,
FIRPTA ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Partnerships ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Exempt Entities ,
Tax Planning ,
Trusts ,
U.S. Treasury