News & Analysis as of

Parent Corporation Subpart F

Rivkin Radler LLP

Enough Already – Eliminate Downward Attribution and Accidental CFCs

Rivkin Radler LLP on

It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more

Proskauer - Tax Talks

Proposed Anti-Hybrid Regulations under Sections 267A, 245A, and 1503(d)

Proskauer - Tax Talks on

On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

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