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Searching Content indexed under Corporate/Commercial Law by David S. Miller ordered by Published Date Descending.
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Final IRS Regulations Sync Section 956 With TCJA Participation Exemption – Limits "Deemed Dividends" For U.S. Corporate Shareholders Of CFCs
Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC shareholders.
United States
14 Jun 2019
2
Proposed FDII Regulations Under Section 250
On March 4, 2019, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") released proposed regulations (the "Proposed Regulations")
United States
7 May 2019
3
Proposed Anti-Hybrid Regulations Under Sections 267A, 245A, And 1503(d)
On December 20, 2018, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") ...
United States
30 Jan 2019
4
IRS Releases Interim Guidance On New Excise Tax On Executive Compensation Paid By Tax-Exempt Organizations
On December 31, 2018, the Department of the Treasury ("Treasury") and the Internal Revenue Service (the "IRS") released Notice 2019-09 (the "Notice"),
United States
18 Jan 2019
5
The Proposed BEAT Regulations
On December 13, 2018, the Internal Revenue Service and the Department of the Treasury released proposed regulations with respect to the "base erosion and anti-abuse tax" under section 59A of the Internal Revenue Code.
United States
7 Jan 2019
6
House Of Representatives Passes The Tax Cuts And Jobs Act (H.R. 1); Senate Finance Committee Approves Modified Version; Comparison Of The Bill Passed By The House And The Modified Senate Bill
Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10.
United States
21 Nov 2017
7
IRS Issues Guidance On "North-South" Transactions
The Ruling, under the facts set forth under Situation 1, spells out the paradigmatic case of a "north-south" transaction.
United States
17 May 2017
8
UPDATE: President Trump Signs "Johnson Amendment" Executive Order Limiting Treasury's Actions Against Religious Organizations Engaged In Political Campaign Activities
On May 4, 2017, President Trump signed an executive order that directs the executive branch to limit its enforcement of the "Johnson Amendment."
United States
10 May 2017
9
Tax Court Rules That Extensions Of Variable Prepaid Forward Contracts Do Not Result In Taxable Exchanges
Last week, in McKelvey v. Commissioner¸ the U.S. Tax Court held that the extension of a typical VPFC did not give rise to a taxable exchange to the obligor because a VPFC is solely an obligation...
United States
2 May 2017
10
Proposed Regulations Under Section 355 Clarify Device And Active Trade Or Business Requirements For Tax-Free Spin-offs
First, the proposed regulations clarify the "device" test and its relationship to the "business purpose" requirement.
United States
29 Jul 2016
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