On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more
11/13/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Financial Services Industry ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
Popular ,
Proposed Regulation ,
Revenue Procedures ,
Safe Harbors ,
Subpart F ,
Tax Reform
Introduction -
On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section...more
4/30/2019
/ Anti-Abuse Rule ,
Capital Gains ,
Carried Interest ,
Holding Periods ,
Opportunity Zones ,
Original Use ,
Partnerships ,
Preamble ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments ,
REIT ,
Reporting Requirements ,
S-Corporation ,
Safe Harbors ,
Tax Cuts and Jobs Act
On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more
4/23/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
Tax Reform
On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and...more
1/28/2019
/ Anti-Abuse Rule ,
BEPS ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Income Taxes ,
IRS ,
Parent Corporation ,
Proposed Regulation ,
Subpart F ,
Tax Reform
On December 13, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) with respect to the “base erosion and anti-abuse...more
1/2/2019
/ Banks ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Corporate Taxes ,
Federal Reserve ,
Foreign Corporations ,
Foreign Taxpayers ,
Insurance Industry ,
IRS ,
Net Operating Losses ,
Preamble ,
Proposed Regulation ,
Recordkeeping Requirements ,
REIT ,
S-Corporation ,
Securities Dealers ,
TLAC ,
U.S. Treasury