Seth Eaton Discusses Modifications and Workouts of Commercial Real Estate Loans during the COVID-19 Pandemic
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
On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of the Internal Revenue Code of...more
In This Issue: - Congress Passes Year-End Tax Extenders Bill - House Adopts New “Dynamic Scoring” Rule - Foreign Fund Engaged in Lending and Stock Distribution Not Protected by “Trading in Stock or Securities”...more
In This Issue: - As FATCA Begins, IRS Rolls out Withholding Forms, Increases IGA Count - IRS Issues Final Circular 230 Rules Simplifying Written Tax Advice Requirements - Mortgage CCA Raises More...more