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Articles by Greg Featherman
IRS Issues Final And Proposed Regulations Clarifying Section 892 Exemption For Foreign Government Investors
WG Weil, Gotshal & Manges LLP More Founded in 1931, Weil has provided legal services to the largest public companies, private equity firms and financial institutions for more than 90 years. Widely recognized by those covering the legal profession, Weil’s lawyers regularly advise clients globally on their most complex Litigation, Corporate, Restructuring, and Tax, Executive Compensation & Benefits matters.
Treasury and IRS issue final rules relating to repatriation of IP
On October 9, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”), which, in certain cases, terminate the continued application of Section 367(d) of the Internal Revenue Code (the “Code”) from a previous transfer of intangible property to a foreign corporation when the intangible property is repatriated to certain U.S. persons. Background.
New IRS Proposed Regulations Address Dual Consolidated Loss Rules
On August 6, 2024, the Treasury Department (“Treasury”) issued Proposed Regulations (REG- 102144-04) (the “Proposed Regulations”) regarding section 1503(d) of the Internal Revenue Code.
Easy as ABC - IRS Issues Final Rules Aimed at Stymieing Killer Bs
On July 17, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations under Section 367(b) of the Internal Revenue Code (the “Code”) that provide guidance applicable to: the treatment of property used to acquire parent stock or securities in connection with certain triangular reorganizations involving one or more foreign corporations; the consequences to persons that receive parent stock or securities pursuant to those reorganizations; and...
IRS Issues Final Regulations for Foreign Investment in Qualified Investment Entities (REITS and RICS)
Overview On April 24, 2024, the Internal Revenue Service (“IRS”) and Treasury Department issued final regulations (T.D. 9992) under section 897 of the Internal Revenue Code of 1986, as amended (the “Code,” and such final regulations, the “Final Regulations”) detailing, among other things, whether a qualified investment entity (“QIE”) is domestically controlled for purposes of section 897(h)(2) of the Code (the “DC-QIE Exception”), and providing much needed clarification regarding the proper...
IRS Releases Guidance to Clarify Corporate AMT Calculations
The Inflation Reduction Act of 2022 (“IRA”) introduced a corporate alternative minimum tax (“CAMT”) on an “applicable corporation’s” (“Applicable Corporation”) financial statement income. The CAMT is applicable for taxable years beginning after December 31, 2022 and imposes a 15% minimum tax on a corporation’s “applicable financial statement income” (“AFSI”).
IRS Issues Guidance on Foreign Tax Credit and Global Minimum Tax
On December 11, 2023, the Internal Revenue Service (“IRS”) released Notice 2023-80 (the “Notice”) establishing the intentions of the Treasury Department (“Treasury”) and the IRS to issue proposed regulations addressing the application of the foreign tax credit (“FTC”) rules and dual consolidated loss (“DCL”) rules with respect to certain taxes under the Pillar Two global anti-base erosion (“GloBE”) rules.
Killer Bs Get Stung - IRS Issues Proposed Rules Aimed at Triangular Reorganizations and Inbound Non-recognition Transactions
On October 5, 2023, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued long awaited proposed regulations under Section 367(b) of the Internal Revenue Code (the “Code”) providing guidance on the use of property to acquire parent stock or securities in connection with certain cross border triangular reorganizations, colloquially referred to as ‘Killer B’ transactions (the “Proposed Regulations”).
IP Phone Home - IRS Issues New Proposed Rules on the Repatriation of Intangible Property
Section 367(d) of the Internal Revenue Code (the “Code”) provides rules for outbound transfers of intangible property (e.g., intellectual property) by a U.S. person (a “U.S. transferor”) to a foreign corporation.
Notice 2023-7 Provides Guidance for Applying Corporate Alternative Minimum Tax
The Inflation Reduction Act of 2022 (“IRA”) introduced a corporate alternative minimum tax (“CAMT”) on an “applicable corporation’s” (“Applicable Corporation”) financial statement income. The CAMT is applicable for taxable years beginning after December 31, 2022 and imposes a 15% minimum tax on a corporation’s “applicable financial statement income” (“AFSI”).
Practical PFIC Considerations in Connection with SPACs | JD Supra
A number of practical considerations must be taken into account in connection with the formation and operation of a non-U.S. special purpose acquisition company (“SPAC”) to mitigate the potential risk of the non-U.S. SPAC being treated as a passive foreign investment company (“PFIC”) for U.S. federal income tax purposes.
The Treasury Department Releases Final and Proposed PFIC Regulations | JD Supra
[co-author: Kerri Gallagher] On December 4, 2020, the IRS released final regulations (T.D. 9936) and proposed regulations (REG-111950-20) relating to the modification of the passive foreign investment company (PFIC) rules. These regulations contain rules for determining when a foreign corporation is classified as a PFIC and whether a U.S. person indirectly holding stock in a PFIC is treated as a shareholder of that PFIC.
Final Section 864(c)(8) Regulations – Some Relief for Certain Non-U.S. Partners | JD Supra
On September 21, 2020, the IRS finalized regulations (the “Final Regulations”) under section 864(c)(8) of the Internal Revenue Code (the “Code”). The Final Regulations generally impact foreign partners in partnerships engaged in a U.S. trade or business and generally retain the approach of proposed regulations that were issued on December 20, 2018 (REG-113604-08) (the “Proposed Regulations”), with certain revisions.
Relief From the Repeal of Section 958(b)(4) Downward Attribution | JD Supra
On September 21, 2020, the IRS released for publication final regulations (T.D. 9908) relating to the modification of section 958(b) by the Tax Cuts and Jobs Act (“TCJA”). These regulations affect U.S. persons that have ownership interest in, or that make or receive payments to or from, certain foreign corporations. By way of background, section 958(b)(4) prevented “downward attribution” of stock owned by a foreign person to a U.S. person.
Final Debt/Equity Regulations | JD Supra
On May 13, 2020, the IRS finalized the “debt/equity” regulations under Section 385 by publishing T.D. 9897. These final regulations implement the 2016 proposed regulations1 (the “2016 Proposed Regulations”) that cross referenced temporary regulations2 (the “2016 Temporary Regulations”) issued in 2016. There were no substantive changes in the final regulations from the 2016 Proposed Regulations or the 2016 Temporary Regulations.
COVID-19 – Benefiting from Worthless Stock Losses | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Guidance on Certain Net Operating Loss Elections Under the CARES Act | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Anti-Hybrid Rules: The IRS Issues Final & Proposed Regulations | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
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