News & Analysis as of

Safe Harbors Controlled Foreign Corporations

Miller Canfield

US Issues Final Regulations on FEOC Exclusions from Clean Vehicle Credit

Miller Canfield on

On May 6, 2024, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) published final regulations (Final Regulations) regarding clean vehicle tax credits under Internal Revenue Code sections 25E...more

Proskauer - Tax Talks

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

Proskauer - Tax Talks on

On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more

Kramer Levin Naftalis & Frankel LLP

The Service Grants Relief to US Shareholders of “Foreign-Controlled” CFCs

On Oct. 1, the Internal Revenue Service (the Service) issued Revenue Procedure 2019-40 (the Revenue Procedure), which offers guidance relating to ownership by certain U.S. persons of stock in “controlled foreign corporations”...more

Eversheds Sutherland (US) LLP

Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)

The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more

Holland & Knight LLP

Navigating the Recent U.S. Sanctions on COSCO (Dalian) and Other Chinese Companies

Holland & Knight LLP on

The U.S. Office of Foreign Assets Control (OFAC) on Sept. 25, 2019, designated COSCO Shipping Tanker (Dalian) Co. Ltd. (COSCO Dalian), Kunlun Shipping Company Ltd., and certain other entities and individuals as Specially...more

A&O Shearman

Guidance on CFC ‘Downward Attribution Rules’ Provides Limited Relief to US Taxpayers

A&O Shearman on

On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more

Carlton Fields

Expect Focus - International - March 2018

Carlton Fields on

Trends Against BITS and Investor State Dispute Resolution - In my first Expect Focus International article (http://bit.ly/2G9Demu), I suggested that investors doing business outside the United States should do so in...more

McDermott Will & Emery

New Temporary Regulations Narrow the Application of the Subpart F Active Rents and Royalties Exception

McDermott Will & Emery on

On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Temporary Regulation § 1.954-2T concluding that third party arrangements cannot be taken into account for...more

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