The Situation: On June 14, 2019, the IRS and U.S. Treasury released more than 500 pages of proposed, temporary, and final regulations addressing the taxation of U.S.-controlled foreign corporations.
The Development:...more
6/25/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Tax ,
GILTI tax ,
IRS ,
Multinationals ,
New Rules ,
Partnerships ,
Proposed Regulation ,
Retroactive Taxes ,
Stocks ,
U.S. Treasury
New IRS guidance issued on qualified foreign pension fund exception.
On June 6, 2019, the U.S. Treasury released proposed regulations under Internal Revenue Code section 897(l) providing guidance for "qualified foreign...more
6/13/2019
/ Anti-Abuse Rule ,
FATCA ,
FIRPTA ,
Foreign Corporations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Guidance ,
Pension Funds ,
Proposed Regulation