Key Points - Coming into force on 1 July 2020, EU DAC6 Regulations will require intermediaries in certain cross-border arrangements to disclose activity to tax authorities. - The DAC will apply retroactively to affected...more
On November 3, 2016, the Treasury issued final regulations (T.D. 9792) that set forth guidance on when a controlled foreign corporation (CFC) has a deemed repatriation under Section 956 in ...more
On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued new temporary Treasury regulations addressing the application of Internal Revenue Code Section 956 to certain...more