The passive foreign investment company (“PFIC”) rules generally impose unfavorable tax treatment on certain U.S. shareholders of foreign corporations that generate excess passive income or hold excess passive assets. In...more
The Proposed Regulations allow existing debt and non-debt contracts that now reference LIBOR and other Interbank Offered Rates (IBORs) to transition toward alternative reference rates without triggering tax.
Key...more
10/23/2019
/ Benchmarks ,
Debt Instruments ,
Fair Market Value ,
Inter-Bank Offered Rates (IBORs) ,
Interest Rates ,
International Tax Issues ,
Libor ,
Proposed Regulation ,
Safe Harbors ,
Secured Overnight Funding Rate (SOFR) ,
U.S. Treasury
Introduction and Overview -
The Tax Cuts and Jobs Act (“TCJA”) resulted in the most sweeping changes to the Internal Revenue Code (the “Code”) in decades and will result in countless articles and commentary to address the...more
Final bill retains key aspects of House and Senate proposals with some surprise last-minute modifications.
Key Points:
..The bill adopts, with some modifications, earlier US House and Senate tax reform...more