Regulations to be Issued on Controlled Foreign Corporations’ Previously Taxed Earnings and Profits
The IRS and the Treasury intend to provide regulations that will address issues affecting foreign corporations with previously taxed earnings and profits (PTEP). The regulations
Proposed Regulations Intend to Reduce FATCA Withholding Compliance Burden
Proposed regulations address and intend to reduce taxpayer burden in complying with certain withholding requirements under the Foreign Account Tax Compliance Act (FATCA), Chapter 4
IRS Issues 2019 Updates for Ruling Requests, Technical Advice, and No-Rule Procedures
The IRS has issued its annual revisions to the general procedures for ruling requests, technical memoranda, determination letters, and user fees, as well as areas
Final Transition Tax Regulations Issued
The Treasury and IRS have issued final regulations for determining the inclusion under Code Sec. 965 of a U.S. shareholder of a foreign corporation with post-1986 accumulated
Safe Harbors Provided for Business Payments Made in Exchange for SALT Credits
The IRS has provided safe harbors for business entities to deduct certain payments made to a charitable organization in exchange for a state or local
Interim Guidance for Excise Tax on Excess Remuneration and Parachute Payments
The IRS has issued interim guidance on the excise tax payable by exempt organizations on remuneration in excess of $1 million and any excess parachute
