Jay Geiger

Jay Geiger

Herbert Smith Freehills Kramer

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The Service Grants Relief to US Shareholders of “Foreign-Controlled” CFCs

On Oct. 1, the Internal Revenue Service (the Service) issued Revenue Procedure 2019-40 (the Revenue Procedure), which offers guidance relating to ownership by certain U.S. persons of stock in “controlled foreign corporations”...more

11/11/2019  /  CFCs , Controlled Foreign Corporations , GILTI tax , Income Taxes , Internal Revenue Code (IRC) , IRS , Safe Harbors , SFC , Stock Ownership , Tax Cuts and Jobs Act

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
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