Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt.
On April 4, 2016, the US Department of the Treasury (Treasury) and the...more
4/21/2016
/ Affiliates ,
Anti-Avoidance ,
Consolidated Tax Returns ,
Controlled Groups ,
Cross-Border Transactions ,
Debt ,
Dividends ,
Foreign Corporations ,
Income Taxes ,
IRS ,
Proposed Regulation ,
REIT ,
Related Parties ,
Required Documentation ,
Stocks ,
U.S. Treasury ,
Withholding Tax
A focus on hybrid arrangements, interest deductions, treaty abuse and permanent establishment structures.
On 5 October 2015, the OECD published its highly anticipated final reports in relation to Base Erosion and Profit...more
For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules.
On June 3, 2015, the US Department of the...more
6/11/2015
/ Bright-Line Rule ,
Corporate Taxes ,
Expatriates ,
Foreign Corporations ,
Foreign Ownership ,
GAAP ,
IFRS ,
Inversion ,
IRS ,
Multinationals ,
Pending Legislation ,
Safe Harbors ,
U.S. Treasury
New guidance seeks to curb the incidence of inversions and reduce the associated tax benefits, but also extends beyond inversions.
On September 22, 2014, the US Department of the Treasury (Treasury) and the Internal...more