The U.S. Department of the Treasury and the Internal Revenue Service (IRS) have jointly issued proposed regulations (Proposed Regulations) to address concerns and reduce uncertainty regarding the tax impact of the anticipated...more
10/28/2019
/ Alternative Reference Rates Committee (ARRC) ,
Comment Period ,
Derivatives ,
Federal Reserve ,
Financial Conduct Authority (FCA) ,
Financial Stability Board ,
Interest Rates ,
Internal Revenue Code (IRC) ,
IRS ,
ISDA ,
Libor ,
Proposed Regulation ,
Secured Overnight Funding Rate (SOFR) ,
Tax Liability ,
U.S. Treasury
Highlights -
• In an unanticipated development, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently issued regulations (New Guidance) that significantly modifies the taxation of U.S....more
7/15/2019
/ Controlled Foreign Corporations ,
Domestic Partnership ,
GILTI tax ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Minority Shareholders ,
New Guidance ,
New Regulations ,
Pass-Through Entities ,
Passive Foreign Investment Company ,
S-Corporation ,
Stocks ,
Subpart F ,
U.S. Treasury