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Corporate Taxes › Section 956 › Internal Revenue Code (IRC)

Eversheds Sutherland (US) LLP

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

Eversheds Sutherland (US) LLP on

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

Kramer Levin Naftalis & Frankel LLP

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

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

Eversheds Sutherland (US) LLP

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

Eversheds Sutherland (US) LLP on

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

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