On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the...more
On December 15, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) issued Notice 2024-10 (the “Notice”), providing much needed interim guidance on the application of the Corporate...more
On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more
10/3/2019
/ 1099s ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Reporting Requirements ,
Revenue Procedures ,
Safe Harbors ,
Subpart F ,
Tax Cuts and Jobs Act
On June 14, 2019, the IRS and Treasury finalized the global intangible low-taxed income (GILTI) regulations (T.D. 9866) and issued proposed regulations (REG-101828-19) that will provide significant relief to investors in...more
6/20/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Domestic Partnership ,
Foreign Corporations ,
Foreign Tax ,
GILTI tax ,
Income Taxes ,
Multinationals ,
Partnerships ,
Private Equity Funds ,
Proposed Regulation ,
Subpart F ,
U.S. Treasury
On July 11, 2018, the Treasury Department and the IRS published final Treasury regulations on inversion transactions (the “Final Regulations”). The Final Regulations substantially adopt the temporary Treasury regulations...more
On November 2, 2017, the House Ways and Means Committee (the “House Committee”) released its plan for comprehensive tax reform: the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “House Bill”). Following a week of hearings,...more
11/20/2017
/ Business Income ,
Corporate Taxes ,
EBITDA ,
Energy Tax Incentives ,
Estate Tax ,
Foreign Corporations ,
International Tax Issues ,
Legislative Agendas ,
Local Taxes ,
Mortgage REITS ,
Property Tax ,
Proposed Legislation ,
Repatriation ,
Shareholders ,
Standard Deduction ,
State Taxes ,
Tax Credits ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Trump Administration
The Treasury Department and the IRS released Notice 2015-79 (the “2015 Notice”) on November 19th to further limit expatriation transactions and to supplement the anti-inversion guidance issued by Treasury and the IRS on...more