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Fox Rothschild LLP

US Treasury Department Has Begun Enforcing New Outbound Investment Rules

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The U.S. Department of the Treasury has started enforcing final regulations that restrict, and in some cases prohibit, U.S. companies, funds and individuals from making certain investments in some technology industries owned...more

Fenwick & West LLP

Compliance Deadline Approaches for New Regs Targeting U.S. Investment in Chinese AI, Semiconductors, Quantum Tech

Fenwick & West LLP on

On November 15, the U.S. Department of the Treasury published final regulations to implement its long-awaited “Outbound Investment” Security Program, which the Biden Administration originally introduced in August 2023 under...more

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

DarrowEverett LLP on

The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

McDermott Will & Schulte

Government Releases Final Foreign Tax Credit Regulations on Stewardship and R&E Expenses

McDermott Will & Schulte on

On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit regulations (the “2020 Final Regulations”) that include the allocation and...more

Foley & Lardner LLP

Does an Excise Tax Apply When Company Employees Serve as Directors and Officers of the Company Foundation?

Foley & Lardner LLP on

New proposed IRS regulations clarify that the tax will not apply in most cases when company officers/employees serve as directors and officers of the company foundation for no compensation from the foundation In a prior blog...more

Herbert Smith Freehills Kramer

New Treasury Regulations and IRS Notice Regarding Withholding on Dividend Equivalent Payments to Foreign Holders

Herbert Smith Freehills Kramer on

On Dec. 16, the Internal Revenue Service (IRS) issued final regulations (the new regulations) governing a narrow aspect of rules applicable to withholding on “dividend equivalent payments” made to foreign persons. The new...more

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