On September 8, 2023, the Department of Treasury (the Treasury) and the Internal Revenue Service (the IRS) released Notice 2023-63 (the Notice), which sets forth the Treasury and the IRS’s intent to issue proposed regulations...more
On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service issued proposed regulations (the "Proposed Regulations") that would generally reduce the amount that a corporate U.S. shareholder is required...more
On July 14, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 355 of the Internal Revenue Code that would establish new guidelines under the so-called "device" and "active business" tests....more
7/21/2016
/ Active Business Test ,
Alibaba ,
Control Test ,
Device Test ,
Internal Revenue Code (IRC) ,
Proposed Regulation ,
Recapitalization ,
Revenue Procedure 2016-40 ,
Share Classes ,
Tax-Free Spin-Offs ,
U.S. Treasury ,
Yahoo!
On April 13, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 305(c) of the Internal Revenue Code that would resolve certain issues relating to the amount and timing of deemed distributions...more
4/22/2016
/ Conversion ,
Convertible Debt ,
Corporate Issuers ,
Dividends ,
Foreign Persons ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Reporting Requirements ,
Shareholder Distributions ,
Shareholders ,
Stocks ,
U.S. Treasury ,
Withholding Requirements