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

Debt Dialogue: August 2017 - The IRS Withdraws Proposed ‘Net Value’ Regulations

The IRS announced in July that it has withdrawn proposed regulations (the net value regulations) that provided guidance regarding corporate formations, reorganizations and liquidations of insolvent corporations. Those...more

9/6/2017  /  Commercial Bankruptcy , Corporate Restructuring , Insolvency , Internal Revenue Code (IRC) , IRS , Liquidation , Notification of Withdrawal , Parent Corporation , Reorganizations , Stocks
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