On October 7, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the “Final Regulations”) with respect to the withholding tax imposed under section...more
10/14/2020
/ Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Popular ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On September 1, 2020, the Treasury Department and the Internal Revenue Service (IRS) issued final regulations in T.D. 9910 (the “Regulations”) permitting taxpayers to waive deductions to reduce or eliminate liability for the...more
The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) is expected to be enacted, as early as March 27, 2020. The CARES Act contains tax provisions intended to provide individuals and companies with liquidity as...more
On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more
12/17/2019
/ Controlled Foreign Corporations ,
Corporate Counsel ,
Corporate Taxes ,
Final Rules ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Popular ,
Subpart F ,
Tax Cuts and Jobs Act ,
Treasury Regulations ,
U.S. Treasury
On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more
10/3/2019
/ 1099s ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Reporting Requirements ,
Revenue Procedures ,
Safe Harbors ,
Subpart F ,
Tax Cuts and Jobs Act
The Internal Revenue Service (“IRS”) issued Revenue Procedure 2019-18 that provides a safe harbor provision for professional sports teams that allows a team to treat the value of a traded player, draft pick, or staff members,...more
On October 31, 2018, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (the IRS) released proposed regulations (the Proposed Regulations) under section 956 of the Internal Revenue Code of 1986,...more
On July 11, 2018, the Treasury Department and the IRS published final Treasury regulations on inversion transactions (the “Final Regulations”). The Final Regulations substantially adopt the temporary Treasury regulations...more
The Tax Cuts and Jobs Act of 2017 (the “Act”) made significant changes to U.S. federal tax law. One of these changes was the establishment of a new tax regime relating to qualified opportunity zones (“Opportunity Zones”)...more
On December 22, 2017, H.R.1, commonly referred to as the Tax Cuts and Jobs Act (“Tax Act”) was signed into law. The Tax Act made the most significant changes to the U.S. tax code since 1986, and will have an effect on...more