Final IRS Regulations Sync Section 956 with TCJA Participation Exemption – Limits “Deemed Dividends” for U.S. Corporate Shareholders of CFCs

Proskauer - Tax Talks

Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC shareholders.


In anticipated and important guidance, the U.S. tax authorities have issued final regulations under I.R.C. Section 956 (the “New 956 Regulations”).[1] The New 956 Regulations are intended to eliminate, in most situations, the “deemed-dividend” issue with respect to controlled foreign corporations (“CFCs”) that are subsidiaries of U.S. corporations, including where the U.S. domestic corporation is a partner in a partnership.

The New 956 Regulations achieve this result by generally giving a U.S. corporation’s income inclusions under Section 956 the same benefit of the U.S.’s limited participation exemption[2] that is otherwise available to actual dividends received from a CFC. The impact of Section 956 on noncorporate U.S. entities (which generally do not benefit from the participation exemption), including where the noncorporate entity is a partner in a partnership, is generally unchanged by the New 956 Regulations. The New 956 Regulations finalize, with limited but important changes, proposed regulations from November 2018.

An immediate impact of the New 956 Regulations will be on the use of non-U.S. subsidiaries to secure borrowings by U.S. corporations. A U.S. borrower generally should now be able to grant lenders complete pledges of stock of CFCs and provide full security interests in the assets of CFCs (and so-called CFC Holdcos — i.e. borrower subsidiaries that hold CFC stock) as long as the CFCs are directly or ultimately owned, in whole, by U.S. domestic corporations and partnerships where all of the direct and indirect partners are either U.S. domestic corporations or entities not subject to U.S. income tax (e.g., tax-exempts, foreign investors) without negative U.S. federal income tax consequences. Under existing Section 956 regulations, the effective limit to avoid phantom dividend income was a pledge of 65% of the voting stock in the CFC, with no guarantee by the CFC. The New 956 Regulations should end the position that new loan agreements must include the old, limited 65% voting stock pledge to protect U.S. corporate borrowers – which was an arguable residual concern while the regulations were still proposed.

The New 956 Regulations also provide a welcome change for multinationals with substantial previously taxed income (“PTI”) under the CFC rules relating to certain hypothetical distributions under the ordering rules for PTI.

These final regulations were issued and became effective on May 23, 2019 (with lookback effectiveness to taxable years beginning after December 31, 2017 in certain circumstances).

 A detailed description of the New 956 Regulations, along with background, a description of the U.S. tax authorities’ explanation of the provisions and discussion of differences from the proposed regulations, continues below.

Background and Context

The New 956 Regulations, issued by the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”),[3] finalized proposed regulations published on November 5, 2018[4] (the “Proposed 956 Regulations”).

A “United States shareholder”[5] of a CFC[6] generally must include its pro rata share of the CFC’s undistributed earnings attributable to an investment in “United States property” (such income amount, a “Section 956 deemed dividend”) in computing its U.S. taxable income.[7] The rule had broad application under the prior regulations, and a deemed dividend would arise from actual investments by the CFC in the United States (e.g., a related party loan to a domestic affiliate), as well as through actions deemed to constitute an indirect U.S. investment – namely guarantees by a CFC and pledges of more than 2/3 of the CFC’s voting stock (or any of its assets) to secure a United States shareholder’s debt.[8] The rule was intended to subject to current U.S. income tax investments of CFC earnings that were “substantially the equivalent of a dividend” – as under prior law, an actual dividend distribution from a CFC to a taxable U.S. shareholder (regardless of its identity) was fully subject to U.S. tax.

The Tax Cuts and Jobs Act, however, changed the treatment of distributions by a CFC to a corporate United States shareholder. The new law introduced a modified form of participation exemption, which allows a U.S. corporation to deduct distributions by CFCs of foreign-source earnings that would otherwise be taxable as dividends in computing U.S. corporate income tax.[9] The Act, however, did not substantially modify Section 956.

In the preamble to the Proposed 956 Regulations, the Treasury and the IRS acknowledged the misalignment between the participation exemption result with respect to actual distributions from a CFC and the Section 956 deemed dividend inclusion resulting from investment in United States property. The Proposed 956 Regulations provided that United States shareholders of a CFC that are exempted U.S. corporations would not be required to include a Section 956 deemed dividend in income resulting from shares it owns in that CFC (such amount, the “tentative Section 956 amount”) to the extent that such Section 956 deemed dividend would be excluded from income if it was paid as an actual distribution under Section 245A (a “hypothetical distribution”).[10] The intent of the Proposed 956 Regulations was to harmonize the treatment of deemed inclusions with actual distributions under the TCJA participation exemption.

The New 956 Regulations

The New 956 Regulations largely mirror the Proposed 956 Regulations – both in their general harmonizing of Section 956 and the TCJA participation exemption as well as the limitations on this benefit to foreign-source dividends. Specifically, only the foreign-source portion of a dividend a corporate United States shareholder receives from a CFC is generally eligible for the participation exemption under Section 245A. If a CFC has U.S.-source earnings (for example, earnings attributable to U.S.-source dividends paid to a CFC or U.S. effectively connected income earned by a CFC), a portion of its Section 956 deemed dividend may still be subject to current U.S. income tax. Additionally, non-corporate United States shareholders continue to be subject to current U.S. income tax on any Section 956 deemed dividend just as under prior law – which is again consistent with the TCJA participation exemption being available only to corporate United States shareholders.

The Proposed 956 Regulations are discussed in detail in our prior publication (which can be accessed here).

There are two substantial, albeit technical, changes in the New 956 Regulations from the Proposed 956 Regulations. One relates to the treatment of U.S. partnerships with U.S. corporate partners for purposes of the TCJA participation exemption. The second relates to the allocation of an actual distribution amount to prior earnings and profits (“E&P”) of a CFC under Section 959(c), which is critical for tracking the treatment of current and future distributions (whether actual or deemed).

U.S. Corporate Partners in U.S. Partnerships that hold CFC stock

The New 956 Regulations provide rules on the treatment of U.S. partnerships that are United States shareholders of a CFC. The preamble to the Proposed 956 Regulations discussed two possible approaches – reducing the Section 956 deemed dividend amount of a U.S. partnership that is a United States shareholder of a CFC by the amount of the deduction for which its U.S. corporate partners would be eligible on a hypothetical distribution under the TCJA participation exemption, or determining the amount of the Section 956 deemed dividend at the U.S. partnership level without regard to the status of its partners but only a U.S. corporate partner’s distributive share of the Section 956 deemed dividend would potentially not be taxable.[11]

The New 956 Regulations include provisions implementing the first approach. As a result, under the New 956 Regulations:

  1. A U.S. partnership must compute its tentative Section 956 amount, then
  2. The U.S. partnership then reduces that tentative Section 956 amount by the aggregate of the deductions that would be allowed to its U.S. corporate partners under the TCJA participation exemption on a hypothetical distribution.[12]

The New 956 Regulations also provide that the portion of a Section 956 deemed dividend amount allocable to a partner is determined by multiplying the U.S. partnership’s Section 956 deemed dividend amount by the “net hypothetical distribution income of the partner” (i.e., the hypothetical distribution to the partner less the TCJA participation exemption deduction to which the partner would be entitled) over the aggregate of such amount for all partners.[13]

Section 959(c) Allocations to Prior E&P

Section 959(c) provides ordering rules for allocating a distribution amount (both actual distributions and Section 956 “deemed” inclusions) among E&P of a CFC.[14] The main purpose of these ordering rules is to track PTI of a CFC and to apply the rules which generally prevent the current taxation of a CFC’s E&P that had been previously included in U.S. taxable income.

Prior to the New 956 Regulations, the ordering rules under Section 959(c) first allocated a distribution to prior years’ E&P of the CFC that have already been subject to U.S. income taxation under Section 956 (such E&P, the “Section 956 PTI”), then to prior years’ E&P of the CFC that have already been subject to U.S. income taxation under Section 951(a)(1)(A), and then to other E&P of the CFC.[15] Without a specific rule providing otherwise, a hypothetical distribution under the Proposed 956 Regulations would first be allocable to the Section 956 PTI amount, and a distribution of Section 956 PTI is not included within the scope of the TCJA participation exemption.[16] As a result, the allocation of the hypothetical distribution to Section 956 PTI would not reduce the Section 956 deemed dividend inclusion. This treatment of a hypothetical distribution is also inconsistent with how a Section 956 deemed dividend inclusion would be allocated under the ordering rules.[17]

Treasury and the IRS acknowledge this issue in the preamble to the New 956 Regulations,[18] and the New 956 Regulations include an overriding ordering rule when applying Section 959(c) rules to a hypothetical distribution – in essence, providing that none of a hypothetical distribution would be attributable to the Section 956 PTI.[19] This treatment is also consistent with the allocation of a Section 956 deemed dividend to a CFC’s E&P under Section 959– and also furthers the broader intent of the New 956 Regulations, which is harmonizing the results under Section 956 with the effect of the TCJA participation exemption. This should make tracking of PTI by large multinational groups easier, and avoid unexpected mismatches, but care will still need to be taken – especially in situations involving CFCs with earnings that are not eligible for the TCJA participation exemption.

Effective Date Provisions

The New 956 Regulations apply to shareholders of a CFC for the CFC’s taxable years beginning on or after July 22, 2019. However, consistent with the Proposed 956 Regulations, taxpayers may apply the New 956 Regulations to tax years beginning after December 31, 2017, provided that the taxpayer and U.S. persons that are related to the taxpayer consistently apply the New 956 Regulations to all their CFCs.[20]

[1] Unless otherwise stated, all Section references are to the U.S. Internal Revenue Code of 1986, as amended.

[2] Section 245A, added as part of the 2017 tax law (Pub. L. No. 115-97), commonly known as the Tax Cuts and Jobs Act (“TCJA”).

[3] T.D. 9859, 84 Fed. Reg. 23716 (May 23, 2019).

[4] REG–114540–18, 83 Fed. Reg. 55324 (Nov. 5, 2018).

[5] A “United States shareholder” of a controlled foreign corporation generally means any U.S. person that is a 10% or more owner of the voting power or value of the CFC. Section 951(b).

[6] A “controlled foreign corporation” is a non-U.S. corporation more than 50% of the total combined voting power or the total value of the stock of which is owned by one or more United States shareholders. Section 957(a).

[7] Section 956(a).

[8] Treasury Regulation Section 1.956-2(c).

[9] See generally Section 245A.

[10] The tentative Section 956 amount for a United States shareholder is determined for each taxable year of a CFC and the hypothetical distribution is deemed to be made on the last day during the taxable year in which the foreign corporation is a CFC. Treasury Regulation Section 1.956-1(a)(2)(i).

[11] 83 Fed. Reg. at 55327.

[12] Treasury Regulation Section 1.956-1(a)(2).

[13] Treasury Regulation Section 1.956-1(a)(2)(iii).

[14] Section 959(a) provides the general rule excluding PTI from income under Section 951(a), and cross-references to Section 959(c) for relevant ordering rules in applying the exclusion.

[15] Section 959(c).

[16] Section 245A(a) specifically allows the deduction for a “dividend,” which generally is a distribution of current and accumulated E&P of a corporation and generally does not include a distribution of PTI.

[17] Under Section 959(f)(1), a Section 956 deemed dividend is treated as attributable first to earnings and profits previously taxed under Section 951(a)(1)(A) and then to other earnings and profits of the CFC. Therefore, no amount of Section 956 deemed dividend is attributable to Section 956 PTI.

[18] 84 Fed. Reg. at 23716.

[19] Treasury Regulation Section 1.956-1(a)(2)(ii)(C).

[20] Treasury Regulation Section 1.956-1(g)(4).

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Proskauer - Tax Talks | Attorney Advertising

Written by:

Proskauer - Tax Talks

Proskauer - Tax Talks on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.