On Sept. 30, officials from Treasury and the IRS provided an
update on a number of guidance projects relating to international
tax. Speaking at the American Bar Association Section of
Taxation's fall meeting in Boston, the officials discussed
anticipated timing for ongoing and upcoming guidance projects,
including some of those listed in this year's
IRS Priority Guidance Plan. The projects were generally
discussed in two categories – projects anticipated to be
completed by the end of 2016 and projects anticipated to be
completed by the end of 2017.
In 2016, the officials said they anticipated the following
Final regulations under Section 367 (REG-139483-13) addressing
transfers made by U.S. persons of certain property, including
foreign goodwill and going-concern value
Final Section 721(c)
regulations addressing U.S. persons' transfers of certain
property to a partnership that has foreign partners
Final Section 956
regulations addressing treatment as U.S. property of property
held by a controlled foreign corporation in connection with certain
transactions involving partnerships
Section 901(m) regulations addressing
denial of foreign tax credits with respect to foreign income not
subject to U.S. taxation by reason of covered asset
Long awaited Section 987 regulations
addressing branch transactions (as part of a "foreign currency
On the horizon for 2017, the officials said they anticipated the
following guidance projects:
Final Section 7874 regulations
addressing transactions that are structured to avoid the purposes
of Sections 7874 and 367 (so-called
inversion regulations) and new Section 7874 regulations
addressing private placement.
Guidance addressing cloud
transactions (i.e., service v. lease characterization).
Notably absent from the discussion were the
Section 385 regulations addressing related-party lending
transactions. However, on Sept. 30, Treasury sent the Section 385
regulations to the White House Office of Information and Regulatory
Affairs (OIRA) for final review. The OIRA has 90 days to review the
regulations. This review is generally the last step when finalizing
regulations. See OIRA's notice.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
To print this article, all you need is to be registered on Mondaq.com.
Click to Login as an existing user or Register so you can print this article.
1 Nov 2016, Webinar, Washington, DC, United States
When the CEO needs to know the tax impact of selling a subsidiary, will your department be ready? When the private equity owner calls to understand the impact of paying a large distribution, is your response time measured in hours or weeks? Tune into our webcast as we help tax professionals prepare for future transactions and make decisions about what is coming.
10 Nov 2016, Webinar, Washington, DC, United States
Join us November 10 for an economic assessment of the election results. Gregory Daco, head of U.S. macroeconomics at Oxford Economics will illustrate the economic and political impact of the new administration based on Oxford Economics’ models and analysis.
16 Nov 2016, Webinar, Washington, DC, United States
This historic presidential election is showcasing two very different visions for the tax code. Plus, top lawmakers in Congress are staking out key positions on tax reform. Join our webcast to learn what the election results will mean for all these tax proposals. We’ll cover the tax platform of the presidential election winner and discuss how the congressional results will shape the tax agenda. Tune in to find out which tax bills and expiring provisions have a chance in the lame duck session and whether 2
The IRS has announced that it will cease the processing of paper returns at three IRS campuses over the coming years. The three affected locations are Covington, Kentucky, Fresno, California, and Austin, Texas.
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).