On April 4, 2016, the Internal Revenue Service (IRS) and Treasury Department proposed new Treasury regulations that, if finalized, would become retroactively effective to April 4, 2016, and dramatically alter the tax...more
On September 14, 2015, the Internal Revenue Service (the IRS) and Treasury Department proposed new regulations addressing the tax treatment under Section 367 of the Internal Revenue Code (the Code) of certain transfers by...more
9/21/2015
/ Aggregation Rules ,
Arms Length Transactions ,
Controlled Transactions ,
Covenant of Good Faith and Fair Dealing ,
Foreign Corporations ,
Internal Revenue Code (IRC) ,
IRC Section 367 ,
IRS ,
Ordinary Business Exception ,
Outbound Transactions ,
Section 482 ,
Transfer Pricing ,
U.S. Treasury ,
Valuation