News & Analysis as of September 25, 2024

Income Taxes › Section 956

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Questioning Old Regulations

Alston & Bird on 8/1/2019

Our Federal Tax Group reflects on the Third Circuit’s recent SIH Partners v. Commissioner ruling and suggests taking a second look at old Treasury regulations that might not survive judicial scrutiny....more

Upstream guarantees and security by foreign subsidiaries of a U.S. corporate borrower may now be available without adverse U.S....

Hogan Lovells on 6/12/2019

Tax structuring under the previous regime - Prior to the issuance of the final regulations described below, under Section 956 of the Internal Revenue Code of 1986 and its related Treasury Regulations, for U.S. tax...more

Final Section 956 Regulations Open the Door to Foreign Credit Support for US Corporate Borrowers

Latham & Watkins LLP on 6/4/2019

Section 956 final regulations confirm those eligible for territorial dividend exemption can benefit from foreign guarantee and collateral support without incurring US tax. On May 23, 2019, the US Treasury and Internal...more

Final Treasury Regulations Facilitate Foreign Subsidiary Credit Support

Kramer Levin Naftalis & Frankel LLP on 6/4/2019

On May 23, the Department of the Treasury and the IRS published final regulations (the final regulations) under Section 956 of the Internal Revenue Code of 1986, as amended (the Code). ...more

Newly Proposed US Tax Regulations Open Possibility of Full Credit Support from Foreign Subsidiaries

Proskauer Rose LLP on 11/19/2018

On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code (the "Proposed Regulations") that are likely to enhance the availability of...more

Plot Twist – Proposed Regulations Mean Section 956 Did Not Actually Survive Tax Reform Intact

Alston & Bird on 11/16/2018

Our International Tax Group takes stock of new proposed regulations that try to keep Section 956 relevant despite the Tax Cuts and Jobs Act....more

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

Hogan Lovells on 11/15/2018

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

Proposed Treasury Regulations Impact “Deemed Dividend” Tax Rules in Financing Transactions

Moore & Van Allen PLLC on 11/14/2018

Following tax reform at the end of 2017, cash dividends from a foreign corporate subsidiary to a domestic corporate 10 percent shareholder are exempt from U.S. income tax because the shareholder is permitted a...more

New Proposed Rules Limit the Negative Tax Consequences of Section 956 "Deemed Dividends" - Certain Foreign Guarantees and Stock...

Katten Muchin Rosenman LLP on 11/6/2018

On October 31, the Internal Revenue Service (IRS) released proposed regulations (the "Proposed Regulations") under Section 956 that could substantially increase the collateral packages made available by US corporate borrowers...more

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

Wilson Sonsini Goodrich & Rosati on 11/6/2018

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

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Income Taxes › Section 956

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