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

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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

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IRS issues initial guidance on application of Code Section 162(m) as amended by the Tax Cuts and Jobs Act

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On August 21, the Internal Revenue Service (IRS) issued Notice 2018-68 containing much-awaited interpretive guidance on Section 162(m) of the Internal Revenue Code as amended by last year's tax reform act (Tax Act), including...more

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