Corporate Taxes, Dividends, Section 956

An Imperfect Match: Aligning the Deemed Dividend Rule with the Post-Tax Reform DRD

Bracewell LLP on 6/28/2019

Eighteen months after the passage of the Tax Cuts and Jobs Act (TCJA or the Act), tax practitioners and taxpayers alike still are looking to Treasury for guidance to interpret and fill in gaps in the new tax laws. The hasty...more

Fine-tuning the course - Final Regulations enhance symmetry between taxation of actual dividends and section 956 inclusions

Eversheds Sutherland (US) LLP on 5/31/2019

On May 23, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (TD 9859) (the Final Regulations) modifying the application of section 956 of the Internal Revenue...more

Structuring U.S. Debt Facilities in Light of New IRS Rules

Troutman Pepper on 5/8/2019

Until recently, the structuring of debt facilities for U.S. borrowers with foreign subsidiaries has been largely driven by IRS interpretations of section 956 of the Internal Revenue Code, which gave rise to significant tax...more

IRS Paves the Way for Lenders to Obtain Guarantees and Collateral From (and 100% Stock Pledges of) Foreign Subsidiaries

Kramer Levin Naftalis & Frankel LLP on 11/16/2018

Background On Oct. 31, 2018, the Internal Revenue Service issued proposed regulations under Section 956 of the Internal Revenue Code that will eliminate the adverse tax consequences when a U.S. parent corporation (i)...more

Impact of Proposed Regulations under Section 956 on Lending Arrangements Involving U.S. Corporate Borrowers

Proskauer - Tax Talks on 11/15/2018

n October 31, 2018, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) proposed new regulations (the “Proposed Regulations”) that are likely to allow many controlled foreign corporations...more

New IRS proposed regulations under Section 956 substantially reduce "deemed dividend" concerns with respect to pledges and...

Hogan Lovells on 11/15/2018

Until the issuance of the Proposed Regulations described below, under Section 956 of the Internal Revenue Code of 1986 (IRC) and Treasury Regulations thereunder, deemed dividends were potentially created when a U.S. borrower...more

Deemed participation better than no participation? Proposed regulations expand tax-free treatment to section 956 inclusions of...

Eversheds Sutherland (US) LLP on 11/7/2018

On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of the Internal Revenue Code of...more

IRS Chief Counsel Shrugs Off Taxpayer’s Section 956 Gambit

Mintz on 5/29/2014

In a recently released Chief Counsel Advice Memorandum (the “Memorandum”), the IRS Office of Chief Counsel (International) addressed an interesting and somewhat creative internal financing structure deployed by a taxpayer...more

Corporate Taxes › Dividends › Section 956

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