Corporate Taxes, Corporate Counsel, U.S. Treasury

Corporate provisions in Final Regulations under Section 163(j)

Eversheds Sutherland (US) LLP on 8/13/2020

On July 28, 2020, Treasury and the IRS released highly anticipated final regulations under section 163(j) and related amended regulations under sections 382 and 383 (Final Regulations). This legal alert focuses on provisions...more

Treasury and the IRS Release Final Foreign Tax Credit Regulations

McDermott Will & Emery on 12/20/2019

Final regulations relating to the determination of the foreign tax credit following the Tax Cuts and Jobs Act were released earlier this month. Though largely similar to the proposed regulations, taxpayers may be interested...more

Final and Proposed TCJA Foreign Tax Credit Regulations Create Traps and Opportunities

A&O Shearman on 12/17/2019

On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more

Brexit and Other Key Issues for CFOs and Corporate Treasurers

A&O Shearman on 7/14/2016

On June 23, 2016, the UK electorate voted to leave the European Union in an advisory Referendum. We expect the UK Government to commence negotiations to withdraw and to establish a framework for the UK’s new relationship with...more

New "Inversion" Proposed Regulations Inspired By The Pfizer/Allergan Deal May Impact Corporate Tax Planning Strategies

Baker Donelson on 5/11/2016

The Treasury Department has recently promulgated proposed regulations dealing with so-called inversion transactions. Inversion transactions are ones in which a U.S. corporation changes its domicile to a nation with a more...more

U.S. Treasury Department Takes Action to Slow (But Not Stop) Corporate Inversions: A Summary for Executives

BakerHostetler on 9/29/2014

What is an inversion? An inversion is a transaction that results in an existing U.S. company becoming a foreign company or becoming a subsidiary of a foreign parent. Historically, inversions involved U.S. companies...more

“Return of Basis” Repatriation Strategy Tested in Tax Court

Bilzin Sumberg on 9/25/2014

U.S. multinationals literally have trillions of dollars of untaxed earnings purportedly “trapped” offshore because of the associated high U.S. corporate income taxes that would be incurred if these earnings were repatriated...more

Corporate Taxes › Corporate Counsel › U.S. Treasury