New guidance clarifies certain key points on implementing the 1% tax that generally applies to public company stock buybacks and the 15% corporate minimum tax that generally applies to corporations with book income exceeding...more
Section 956 final regulations confirm those eligible for territorial dividend exemption can benefit from foreign guarantee and collateral support without incurring US tax.
On May 23, 2019, the US Treasury and Internal...more
Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects.
On November 26, 2018, the Treasury and...more
12/20/2018
/ C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
GILTI tax ,
Interest Payments ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
REIT ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
U.S. Treasury
But Holding Period and Other Requirements Add Complexity -
On October 31, 2018, the US Treasury and Internal Revenue Service issued proposed regulations (the Proposed Regulations) that would eliminate, in most...more
The one-year postponement assists taxpayers that are developing compliance systems, amidst broader government review of the related-party debt regulations.
On July 28, 2017, the US Department of the Treasury (Treasury) and...more
Decision could open planning opportunities for non-US partners regarding sale of a partnership interest.
The Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner 1 case — which the US Tax Court decided...more
By declaring a controversial ruling obsolete, the IRS removes uncertainty surrounding the tax effects of certain corporate restructuring techniques.
A pair of revenue rulings the US Internal Revenue Service (IRS)...more