Corporate Taxes, Safe Harbors, Proposed Regulation

They have arrived: New York issues “final draft” corporate income tax apportionment regulations

Eversheds Sutherland (US) LLP on 7/20/2022

On July 1, 2022, the New York State Department of Taxation and Finance issued the third set of “final draft” regulations relating to the corporation franchise tax reform that took effect for tax years beginning on or after...more

Weekly IRS Roundup December 9 – 13, 2019

McDermott Will & Emery on 12/18/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

Proskauer - Tax Talks on 11/13/2019

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

Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)

Eversheds Sutherland (US) LLP on 10/14/2019

The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more

Guidance on CFC ‘Downward Attribution Rules’ Provides Limited Relief to US Taxpayers

A&O Shearman on 10/3/2019

On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more

Proposed Regulations on Built-in Gains and Losses under Section 382(h)

Proskauer - Tax Talks on 9/23/2019

On September 10, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) on calculation of built-in gains and losses under...more

Guide to the Surprises Lurking in the QOZ Proposed Regulations

Flaster Greenberg PC on 4/26/2019

While mid-April is typically associated by most with Tax Day, this year, April 2019, also became the month the highly awaited second round of Qualified Opportunity Zone Proposed Regulations were issued....more

Corporate Taxes › Safe Harbors › Proposed Regulation