News & Analysis as of

U.S. Treasury Generally Accepted Accounting Procedures

Cadwalader, Wickersham & Taft LLP

A Worthwhile Proposal for Worthless Debt

In December, Treasury and the IRS issued proposed regulations updating the standard for determining when a debt instrument held by certain banks and insurance regulated entities will be conclusively presumed to be worthless...more

Eversheds Sutherland (US) LLP

Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure: ..Allows controlled...more

McDermott Will & Emery

Proposed Regulations Would Conform Subpart F High-Tax Exception to GILTI High-Tax Exception

On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F...more

Eversheds Sutherland (US) LLP

IRS offers a 162(m) - brace for the holidays

On December 16, 2019, the Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) released long-awaited proposed regulations under Section 162(m) of the Internal Revenue Code implementing changes...more

Eversheds Sutherland (US) LLP

Covered Agreement - An overview

On January 13, 2017, the then-US Secretary of the Treasury and the then-US Trade Representative (USTR) notified Congress that they had negotiated a covered agreement with the European Union (EU). After a period of uncertainty...more

Eversheds Sutherland (US) LLP

Covered Agreement - An overview

On January 13, 2017, the then-US Secretary of the Treasury and the then-US Trade Representative (USTR) notified Congress that they had negotiated a covered agreement with the European Union (EU). After a period of uncertainty...more

Morrison & Foerster LLP

News Round Up - October 2017

Morrison & Foerster LLP on

Treasury Report, Part II: Regulation of the Capital Markets - The U.S. Department of the Treasury (“Treasury Department” or “Treasury”) issued its second report (of four reports), titled “A Financial System that Creates...more

Eversheds Sutherland (US) LLP

US-EU Covered Agreement: An Overview

On January 13, 2017, the then-US Secretary of the Treasury and the then-US Trade Representative (USTR) notified Congress that they had negotiated a covered agreement with the European Union (EU). After a period of uncertainty...more

Latham & Watkins LLP

New Final Inversion Rules Maintain Tight Standard for Corporate Expatriations

Latham & Watkins LLP on

For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules. On June 3, 2015, the US Department of the...more

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