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S-Corporation Passive Foreign Investment Company

Freeman Law

The Section 965 Transition Tax And IRS Audits

Freeman Law on

Section 965 audits are on the rise. Taxpayers under section 965 transition tax audits often face significant potential liability exposure. The IRS previously announced an active “campaign” specifically targeting unpaid...more

Cole Schotz

Carried Interests: Final Capital Gain Recharacterization Rules Released

Cole Schotz on

In the 2017 Tax Act, Congress adopted Code §1061, a provision which affects non-corporate holders of certain carried interests, which the new law refers to as applicable partnership interests (“APIs”). Under the new law,...more

Holland & Knight LLP

New Treasury Regulations Revise Taxation of U.S. Persons Owning Foreign Corporations - Guidance Will Impact Minority Partners in...

Holland & Knight LLP on

Highlights - • In an unanticipated development, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently issued regulations (New Guidance) that significantly modifies the taxation of U.S....more

Proskauer Rose LLP

Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements

Proskauer Rose LLP on

On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding...more

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