Helayne Oberman Stoopack

Helayne Oberman Stoopack

Herbert Smith Freehills Kramer

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Final Treasury Regulations Facilitate Foreign Subsidiary Credit Support

On May 23, the Department of the Treasury and the IRS published final regulations (the final regulations) under Section 956 of the Internal Revenue Code of 1986, as amended (the Code). ...more

6/4/2019  /  Controlled Foreign Corporations , Foreign Subsidiaries , Income Taxes , Internal Revenue Code (IRC) , IRS , New Regulations , Regulatory Agenda , Section 956 , Tax Deductions , U.S. Treasury

Income Inclusions From a Controlled Foreign Corporation or Passive Foreign Investment Company are “Good” Income for a Regulated...

Recently-finalized, regulations provide that, in determining whether a corporation is a regulated investment company (RIC), amounts the corporation is required to include in income as a result of its investment in foreign...more

5/3/2019  /  Amended Regulation , Controlled Foreign Corporations , Investment Companies , Investment Company Act of 1940 , IRS , Passive Foreign Investment Company , Registered Investment Companies (RICs) , Required Minimum Distributions , Securities , U.S. Treasury
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