On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”). The Treaty provides for reduced withholding tax rates on income such as...more
On September 1, 2020, the Treasury Department and the Internal Revenue Service (IRS) issued final regulations in T.D. 9910 (the “Regulations”) permitting taxpayers to waive deductions to reduce or eliminate liability for the...more
The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) is expected to be enacted, as early as March 27, 2020. The CARES Act contains tax provisions intended to provide individuals and companies with liquidity as...more
With the likely increased borrowings or refinancing of debt as a result of the COVID-19 crisis, multinational companies should consider the impact of changes in U.S. tax law made in 2018. As a result of these changes, U.S....more
On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more
12/17/2019
/ Controlled Foreign Corporations ,
Corporate Counsel ,
Corporate Taxes ,
Final Rules ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Popular ,
Subpart F ,
Tax Cuts and Jobs Act ,
Treasury Regulations ,
U.S. Treasury
On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more
10/3/2019
/ 1099s ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Reporting Requirements ,
Revenue Procedures ,
Safe Harbors ,
Subpart F ,
Tax Cuts and Jobs Act
On September 9, 2019, the Treasury Department (“Treasury”) and the Internal Revenue Service (the IRS) issued proposed section 382 regulations (REG-125710-18) (the “Proposed Regulations”) reversing certain previously...more
9/19/2019
/ Acquisitions ,
Change of Ownership ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Mergers ,
Net Operating Losses ,
Proposed Regulation ,
Sale of Assets ,
Startups ,
Tax Cuts and Jobs Act ,
U.S. Treasury ,
Venture Capital