The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more
4/30/2025
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Cloud Computing ,
Digital Assets ,
Final Rules ,
Foreign Affiliates ,
Income Taxes ,
International Tax Issues ,
Multinationals ,
Proposed Rules ,
Regulatory Requirements ,
Service Contracts ,
Software ,
Taxation ,
Third-Party Service Provider ,
U.S. Treasury
The U.S. Department of Treasury (Treasury) recently released proposed regulations under §§ 959 and 961 and related Code sections (REG-105479-18, the “Proposed Regulations”) addressing the treatment of previously taxed...more
Released on September 8, 2023, IRS Notice 2023-63 provides wide-ranging and potentially controversial guidance on the capitalization and amortization of research and experimentation expenses under section 174....more
U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules, which could substantially increase the tax owed on exit for U.S....more
1/9/2020
/ Business Taxes ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Fair Market Value ,
Foreign Corporations ,
GILTI tax ,
Income Taxes ,
Investors ,
IRS ,
Partnerships ,
Passive Investments ,
PFIC ,
Proposed Regulation ,
Startups ,
Subpart F ,
Venture Capital