Proposed regulations addressing new tax reporting requirements for cryptocurrencies and other digital assets have been issued by the IRS and Treasury....more
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
On November 26, 2018, the U.S. Treasury released proposed regulations under section 163(j) of the Internal Revenue Code, which, as amended by last year's tax reform, generally limits deductibility of net business interest...more