Corporate Taxes, Subpart F, International Tax Issues

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

IRS releases Notice 2018-26 - retroactively disregarding certain accounting method changes and entity classification elections

Eversheds Sutherland (US) LLP on 4/10/2018

The Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-26, which provides guidance under section 965 of the Internal Revenue Code regarding the “transition tax.” Section 965 imposes a transition tax...more

Inexplicably, Section 956 Survives Tax Reform Intact

Alston & Bird on 2/16/2018

How did a section of the Internal Revenue Code destined for repeal by both the House and Senate versions of the Tax Cuts and Jobs Act survive the final Act? Our International Tax Group examines the future application of...more

US “TCJ Act” Tightening of CFC Rules Eliminates Common Approach To Post-Death Avoidance Of US Beneficiary Taxation

BCLP on 2/14/2018

On December 22, 2017, President Trump signed into law H.R. 1 (Pub. L. No. 115-97), known as the Tax Cuts and Jobs Act (the “Act”). The Act is the first major overhaul of the Internal Revenue Code (the “Code”) in more than 30...more

Impact of Recent Tax Legislation on M&A Transactions

Proskauer - Tax Talks on 2/12/2018

This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect M&A Transactions. Some of these rules are very complex, particularly in...more

Congress Passes Final Tax Reform Bill: U.S. Tax Reform: The Current State of Play

Sheppard Mullin Richter & Hampton LLP on 12/21/2017

With the affirmative vote in the House today, both Houses of Congress have now passed a final version of the Tax Cuts and Jobs Act, clearing the legislation for President Trump’s signature. President Trump is widely expected...more

House of Representatives Releases First Draft of Tax Reform Bill

Jones Day on 11/7/2017

The Situation: On November 2, 2017, the House Ways and Means Committee released its first draft of much-anticipated comprehensive U.S. tax reform legislation as the "Tax Cuts and Jobs Act." Chairman Brady’s markup of the bill...more

Corporate Taxes › Subpart F › International Tax Issues