Searching Content indexed under Corporate Tax by David E. Sites ordered by Published Date Descending.
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IRS Issues Final Regulations On Information Reporting And Record Maintenance For Certain Disregarded Entities
The Department of the Treasury and the IRS recently released final regulations (T.D. 9796) that treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation...
United States
26 Jan 2017
Treasury Finalizes And Significantly Modifies The Debt-Equity Regulations Under Section 385
New final and temporary regulations under Section 385, addressing the treatment of related-party debt, significantly narrow parts of the controversial proposed regulations released in April.
United States
21 Oct 2016
IRS Rules On Termination Of GRA In Certain Inbound Asset Reorganizations
The IRS released a private letter ruling that held that the acquisition of substantially all the assets of a transferred corporation results in the termination of the associated gain recognition agreement under Section 367.
United States
18 Oct 2016
IRS Adds New International Projects To Priority Guidance Plan
The IRS has added and modified several international guidance projects in the 2016‒2017 Priority Guidance Plan.
United States
4 Oct 2016
U.S. Chamber Of Commerce Challenges Inversion Regulations
In a complaint filed on Aug 4 in the Western District of Texas the US Chamber of Commerce and the Texas Association of Business filed suit against the IRS and Treasury over the inversion regulations.
United States
22 Aug 2016
IRS Issues Final Regs On BEPS Country-By-Country Reporting
The IRS issued final regulations on June 29 that will require U.S. multinationals with more than $850 million in revenue to report specific information on a country-by-country basis for the first time.
United States
21 Jul 2016
European Union Reaches Political Agreement On Anti-Tax Avoidance Directive
The political agreement on the Directive is expected to be submitted to ECOFIN on July 12 and will likely be formally adopted without further discussion.
European Union
12 Jul 2016
Proposed Regulations Would Require More Transparency For Certain Wholly Owned Domestic Disregarded Entities
Specifically, such treatment would apply to reporting, record maintenance and associated compliance requirements that otherwise apply to 25% foreign-owned domestic corporations under Section 6038A.
United States
25 May 2016
Treasury Issues Regulations Targeting Inversions And Related-Party Debt Transactions
The IRS and Treasury on April 4 announced their latest action to limit inversion transactions and address earnings stripping.
United States
20 Apr 2016
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