IRS Withdraws, Reproposes Foreign Currency Gain, Loss Regs
The IRS has released new proposed regulations on making and revoking certain foreign currency gain or loss elections. These new …
Pillar 2 Work Progressing Despite Lack of US Implementation, Treasury Official Says
Although the US has not yet implemented the two-pillar global tax plan from the Organization for Economic Co-operation and Development …
Planning Around Major Changes to the Foreign Tax Credit
By Patricia Brandstetter and Jonathan D. Grossberg Final regulations, issued December 28, 2021 (TD 9959), significantly change longstanding principles for …
US Committed to Global Corporate Minimum Tax Conformity, Biden Team Says
Treasury Secretary Janet Yellen this week is pressing counterparts from the world’s major economies to advance a rewrite of global …
Prop regs on Sec. 965 transition tax: E&P and basis adjustments, affiliated groups, and Sec. 986(c)
IRS has issued proposed regs under Code Sec. 965, the “mandatory repatriation” provision added to the Code by the Tax Cuts …
IRS updates Q&As on return filing and tax payment for Sec. 965 transition tax
IRS has updated Frequently Asked Questions (FAQs) on the transition tax imposed by Code Sec. 965, as added by the Tax …
IRS guidance on Tax Act’s deemed repatriation rules and constructive ownership changes
IRS has issued a Notice and accompanying News Release that provide guidance regarding: a) Code Sec. 965, which was enacted …
IRS issues guidance on Tax Act’s deemed repatriation rules
IRS has issued a Notice and accompanying News Release that provide guidance regarding Code Sec. 965, which was enacted into …