News & Analysis as of

Foreign Corporations Section 956

Locke Lord LLP

IRS Issues Final Regulations under Section 956, With Few Changes from Proposed Regulations

Locke Lord LLP on

Following its issuance of proposed regulations in November of last year, the IRS today published final regulations (84 FR 23716) under Section 956 of the Internal Revenue Code. The final regulations include very few changes...more

Blank Rome LLP

Proposed Treasury Regulations Shift the Landscape in Debt Financings over Collateral of Foreign Subsidiary Stock

Blank Rome LLP on

Proposed Treasury Regulations have been published that will permit many U.S. corporate borrowers to provide a lender with a greater collateral package in respect of its foreign subsidiaries without an adverse tax consequence...more

Wilson Sonsini Goodrich & Rosati

IRS Issues Proposed Regulations Reducing Income Inclusions under Section 956 for Certain U.S. Corporations

On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service issued proposed regulations (the "Proposed Regulations") that would generally reduce the amount that a corporate U.S. shareholder is required...more

Foley & Lardner LLP

The Effect of Tax Reform on Financing Transactions: Thoroughly Review Your Company's Situation

Foley & Lardner LLP on

In general, the effects of the new tax law should be very favorable to most corporate borrowers. Nevertheless, there may be situations where a corporate borrower benefits economically from a lower tax rate and other favorable...more

Alston & Bird

Inexplicably, Section 956 Survives Tax Reform Intact

Alston & Bird on

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

Proskauer - Tax Talks

Impact of Recent Tax Legislation on M&A Transactions

Proskauer - Tax Talks on

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

Proskauer - Tax Talks

The Senate Finance Committee’s proposal for tax reform, and how it compares with the bill passed by the House Committee on Ways &...

Proskauer - Tax Talks on

UPDATE: The Senate Finance Committee last night released a revised version of the Chairman’s Mark of the Tax Cuts and Jobs Act. We are reviewing these changes and will release an update soon... On Thursday, November 9, the...more

Bilzin Sumberg

Cancellation of CFC Loans to US Shareholders – Should the Service Get a Second Bite at the Apple?

Bilzin Sumberg on

The Service generally has three years after a return is filed to assess any tax due for that year. There are a number of exceptions to this general rule, such as where a taxpayer files a false return or omits more than 25...more

Lowndes

Further Crackdown on Offshore Corporations

Lowndes on

In their continued effort to crackdown on offshore activity, the IRS and Treasury released proposed regulations yesterday that target debt held by foreign partnerships. These regulations provide that debt held by foreign...more

Bilzin Sumberg

IRS Taking Closer Look at Section 956 Inclusions

Bilzin Sumberg on

Each “U.S. Shareholder” of a controlled foreign corporation (“CFC”) is required to include in their gross income as a deemed distribution their pro rata share of the amount determined under section 956 for that year (i.e.,...more

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