News & Analysis as of

Cross-Border Transactions Proposed Regulation U.S. Treasury

Eversheds Sutherland (US) LLP

IRS and Treasury notice proposes removal of disregarded payment loss rules and changes to dual consolidated loss rules

On August 20, 2025, the Internal Revenue Service (IRS) released Notice 2025-44 (Notice), which announced that the Department of the Treasury (Treasury) and IRS intend to issue proposed regulations that would...more

Jones Day

New Guidance from the Treasury Department on 1% Corporate Stock Buyback Tax

Jones Day on

On April 9, 2024, the U.S. Treasury Department ("Treasury") issued proposed regulations and reporting requirements providing further guidance on the non-deductible 1% excise tax that was enacted on August 16, 2022 (as Section...more

Torres Trade Law, PLLC

CFIUS Updates: New FAQs Clarify Positions; Possible Expansion of Scope of Real Estate Review

Torres Trade Law, PLLC on

In our recent article Amid TikTok Tensions, CFIUS Signals Increased Enforcement and Other Updates, we discussed updates from the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”) primarily with...more

A&O Shearman

CFIUS Proposes Filing Fees for Transaction Reviews

A&O Shearman on

The U.S. Department of the Treasury late yesterday released a draft set of regulations that would establish, for the first time, filing fees for most transactions submitted to the Committee on Foreign Investment in the United...more

Fenwick & West LLP

Proposed Guidance on the Production Sourcing Rules under New Section 863(b)

Fenwick & West LLP on

The Tax Cuts and Jobs Act (TCJA) repealed the long-standing “50/50” sourcing rule for United States exporters of manufactured products. Under the new rules, which source income of a “producer” solely to the place of...more

McDermott Will & Schulte

Weekly IRS Roundup December 23 – 27, 2019

McDermott Will & Schulte on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

Dorsey & Whitney LLP

CFIUS and Its Proposed Regulations Expanding Jurisdiction - Foreign Investment in the United States will Face More National...

Dorsey & Whitney LLP on

The U.S. Department of the Treasury’s Office of Investment Security published proposed regulations on September 24 (“Proposed Regulations”). Under the Proposed Regulations, more foreign investment transactions will be subject...more

WilmerHale

CFIUS Publishes New Proposed Regulations

WilmerHale on

The US Department of the Treasury recently published for public comment two proposed regulations that will expand the jurisdiction of the Committee on Foreign Investment in the United States (CFIUS) and make substantive...more

Sheppard Mullin Richter & Hampton LLP

Proposed Rule Expands CFIUS Jurisdiction to Real Estate Investments That Pose a National Security Risk; Could Have Major Impacts...

What is CFIUS? The Committee on Foreign Investment in the United States, or CFIUS, is an interagency committee chaired by the Secretary of the Treasury which is authorized to review and approve transactions involving foreign...more

McDermott Will & Schulte

Expanded CFIUS Review over Non-Controlling Foreign Investments in US Businesses and Foreign Investments in Certain US Real Estate

The US Treasury Department issued proposed regulations that would “comprehensively” implement legislation passed last year, FIRRMA, to broaden the jurisdiction of CFIUS. Interested parties have until October 17 to file...more

Akin Gump Strauss Hauer & Feld LLP

Treasury Releases Proposed CFIUS Regulations to Implement FIRRMA

• The U.S. Department of Treasury released proposed rules implementing the Foreign Investment Risk Review Modernization Act (FIRRMA) on September 17, 2019. Among other measures, these rules would establish how the Committee...more

Womble Bond Dickinson

Proposed US Tax Rules for Cloud Computing Transactions and Digital Downloads – International Implications Are a Reason to Review

Womble Bond Dickinson on

On August 9, 2019, the US Treasury Department published proposed regulations for the classification of “cloud transactions” and “transactions involving digital content” under the source of income rules of the Internal Revenue...more

Seyfarth Shaw LLP

One Step Back, One Step Forward: New Debt-Equity Regulations Narrow Their Focus on Earnings Stripping

Seyfarth Shaw LLP on

Seyfarth Synopsis: On October 13, 2016 the IRS and Treasury Department published over 500 pages of final and temporary regulations under Code Section 385 (the “Final Regulations”). Drafted to curtail tax benefits accrued by...more

Latham & Watkins LLP

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Latham & Watkins LLP on

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

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