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Securities Controlled Foreign Corporations

Kramer Levin Naftalis & Frankel LLP

Income Inclusions From a Controlled Foreign Corporation or Passive Foreign Investment Company are “Good” Income for a Regulated...

Recently-finalized, regulations provide that, in determining whether a corporation is a regulated investment company (RIC), amounts the corporation is required to include in income as a result of its investment in foreign...more

Dechert LLP

IRS Releases Final Tax Regulations on Imputed Income from Subsidiaries and Other Controlled Foreign Corporations

Dechert LLP on

On March 18, 2019, the U.S. Department of the Treasury and the Internal Revenue Service issued final tax regulations for registered investment funds that are taxed as regulated investment companies (“RICs”) and that invest in...more

Eversheds Sutherland (US) LLP

Spinning in circles, Treasury resumes original course on regulated investment company income rules

On March 19, 2019, the Internal Revenue Service (IRS) and Treasury Department (Treasury) issued final regulations (T.D. 9851) (Final Regulations) under section 851 addressing the income test applicable to regulated investment...more

Troutman Pepper

The IRS's Stricter(?) Stance on Regulated Investment Company Investments in Commodities - Tax Update Volume 2017, Issue 1

Troutman Pepper on

While the IRS's Proposed Regulations Are Not Yet Effective, RICs Should Carefully Consider Whether Their Portfolios or Policies Run Afoul of the New Rules. In order for a corporation to qualify as a regulated investment...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review - September 9, 2013

Agency Template for Tailored Resolution Plans - On September 3, the FDIC and the Fed released an optional model template for tailored resolution plans required to be submitted by the Dodd-Frank Act. SEC Risk...more

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