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International Tax Issues › Corporate Taxes › Final Rules

McDermott Will & Schulte

IRS announces intent to withdraw controversial DPL rules

McDermott Will & Schulte on

The US Department of the Treasury and the Internal Revenue Service (IRS) recently issued Notice 2025-44, announcing their intent to withdraw the controversial disregarded payment loss (DPL) rules finalized at the end of the...more

Latham & Watkins LLP

Passive Foreign Investment Companies: Reinterpreting the Active Banking Exception for the Modern Banking Industry

Latham & Watkins LLP on

The passive foreign investment company (“PFIC”) rules generally impose unfavorable tax treatment on certain U.S. shareholders of foreign corporations that generate excess passive income or hold excess passive assets. In...more

Fenwick & West LLP

Treasury and IRS Release Final and Proposed Foreign Tax Credit Regulations

Fenwick & West LLP on

On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more

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