On October 31, 2018, the Treasury Department released proposed regulations (the “Proposed Regulations”) that reduce certain amounts otherwise includible in the taxable income of a corporate U.S. shareholder of a controlled...more
11/27/2018
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Controlled Foreign Corporations ,
Corporate Taxes ,
Distribution Rules ,
Financial Guarantee Requirements ,
IRS ,
Multinationals ,
Proposed Regulation ,
Section 956 ,
Stocks ,
Tax Cuts and Jobs Act ,
U.S. Treasury ,
Voting Shares
The U.S. Treasury Department issued new proposed tax regulations that would re-characterize certain related party debt as equity, resulting in dividend payments rather than tax deductible interest payments. If finalized in...more