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U.S. Treasury › Applicability Date

Fenwick & West LLP

The FDII Final Regulations Are Here: An Executive Summary and Observations

Fenwick & West LLP on

Treasury and the IRS released final section 250 regulations on July 9, 2020, primarily focused on the deduction for foreign-derived intangible income (FDII). The final regulations make significant revisions to the proposed...more

Proskauer - Employee Benefits & Executive...

Treasury and IRS Issue Eagerly-Awaited Guidance on Hardship Distributions – with a Few Surprises

Proskauer - Employee Benefits & Executive... on

Last Friday, the IRS issued eagerly-awaited proposed regulations regarding hardship distributions under section 401(k) and 403(b) plans (the “Proposed Regulations”). The Proposed Regulations primarily address hardship...more

Proskauer - Tax Talks

IRS Eliminates Signatures on Section 754 Elections, Offering Tax Regulatory Reform Preview (and its Complexity?)

Proskauer - Tax Talks on

In a notice of proposed rulemaking issued on October 11, 2017 (the “NPRM”), the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) proposed an amendment to existing regulations (the...more

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