New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions.
On April 4, 2016, the US Department of the Treasury (Treasury) and...more
4/21/2016
/ Acquisitions ,
Anti-Inversion Regulations ,
Controlled Foreign Corporations ,
Controlled Groups ,
Corporate Taxes ,
De Minimus Quantity Exemption ,
Dividends ,
Foreign Corporations ,
Inversion ,
IRS ,
Multinationals ,
Proposed Regulation ,
Related Parties ,
Stocks ,
U.S. Treasury
Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt.
On April 4, 2016, the US Department of the Treasury (Treasury) and the...more
4/21/2016
/ Affiliates ,
Anti-Avoidance ,
Consolidated Tax Returns ,
Controlled Groups ,
Cross-Border Transactions ,
Debt ,
Dividends ,
Foreign Corporations ,
Income Taxes ,
IRS ,
Proposed Regulation ,
REIT ,
Related Parties ,
Required Documentation ,
Stocks ,
U.S. Treasury ,
Withholding Tax
For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules.
On June 3, 2015, the US Department of the...more
6/11/2015
/ Bright-Line Rule ,
Corporate Taxes ,
Expatriates ,
Foreign Corporations ,
Foreign Ownership ,
GAAP ,
IFRS ,
Inversion ,
IRS ,
Multinationals ,
Pending Legislation ,
Safe Harbors ,
U.S. Treasury