Modeled after the Foreign Account Tax Compliance Act (FATCA) – the U.S.’s information reporting regime for U.S. holders of foreign accounts – the Organisation for Economic Co-Operation and Development (OECD) approved the...more
The Tax Court, in American Metallurgical Coal Co., TC Memo 2016-139, recently held that financing of a sale of partnership interests by a foreign seller to a U.S. buyer was not debt, but equity. The court found that the...more
In recent Notice 2016-42, the IRS has proposed a new qualified intermediary (QI) agreement. The current QI agreement, set forth in Rev. Proc. 2014-39 (“the 2014 QI agreement”), expires December 31, 2016. The IRS expects to...more
In late September, the IRS issued final regulations describing six requirements for a transaction or series of transactions to qualify as a reorganization under Section 368(a)(1)(F) (an “F reorganization”). The IRS...more