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 ,
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On December 22, 2017, President Trump signed the bill popularly referred to as the “Tax Cuts and Jobs Act” (the “Act”) into law. The Act contains significant changes to Section 162(m) of the Internal Revenue Code that are...more