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Treasury and IRS Release Final and Proposed Foreign Tax Credit Regulations

On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

New Field Attorney Advice Explores the Intersection of § 1253 with the Anti-Churning Rules of § 197

A new IRS legal advice memorandum addresses a fact pattern that may become more common in the wake of Tax Reform—sale of intangible property from a controlled foreign corporation to its United States parent—and highlights the...more

Recent Tax Court Decision in Crestek – a Cautionary Tale for U.S. Companies with Foreign Subsidiaries

In a ruling with tax implications for U.S. corporations with foreign subsidiaries, the U.S. Tax Court has held that transactions between a U.S. parent company and its controlled foreign corporations constitute “United States...more

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