IRS delivers a surprise in proposing new regs.
New rules would generally conform the tax treatment of deemed dividends to the treatment of actual dividends for US corporations that own foreign subsidiaries, creating the...more
On July 13, 2017, in Grecian Magnesite Mining, Industrial and Shipping Co. SA v. Commissioner (149 T.C. No. 3 (2017), the U.S. Tax Court concluded that gain recognized by a foreign corporation upon redemption of its interest...more