On April 23, 2020, the Treasury Department and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 512(a)(6) of the Internal Revenue Code (the “Code”). Section...more
On August 21, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-67 (the “Notice”), addressing issues relevant to tax-exempt organizations arising under new Section 512(a)(6) of the Internal Revenue Code (the...more
9/5/2018
/ Controlled Foreign Corporations ,
GILTI tax ,
Income Taxes ,
IRS ,
NAICS ,
Partnerships ,
Public Comment ,
Reporting Requirements ,
Tax Exempt Entities ,
Tax Exemptions ,
UBTI