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IRS Issues Proposed Regulations Reducing Income Inclusions under Section 956 for Certain U.S. Corporations

On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service issued proposed regulations (the "Proposed Regulations") that would generally reduce the amount that a corporate U.S. shareholder is required...more

IRS Releases Final Regulations Addressing Corporate Inversions and Related Transactions

On July 11, 2018, the U.S. Treasury Department and the Internal Revenue Service (the IRS) issued final regulations under Section 7874 and related sections of the Internal Revenue Code of 1986, as amended, (the Code)...more

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