On July 23, 2015, the Internal Revenue Service (“IRS”) issued a Notice of Proposed Rulemaking (the “Notice”) which proposed Treasury regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the...more
In This Issue:
- Deferred Earnings and Profits of CFCs
- Code Section 956(e)
- Code Section 7701(l)
- Code Section 304(b)(5)(B)
- Code Section 7874
- Request for Comments
-...more
In This Issue:
- Solar Sites
- The Proposed Regulations
- Intangible Assets
- Distinct Assets
- Examples in the Proposed Regulations
- Effective Date
- Excerpt from Solar Sites:
A key...more
On January 29, 2014, the Internal Revenue Service (IRS) proposed Treasury regulations under Section 752 of the Code which would change the way in which both partnership recourse and nonrecourse liabilities are allocated. The...more