Released on September 8, 2023, IRS Notice 2023-63 provides wide-ranging and potentially controversial guidance on the capitalization and amortization of research and experimentation expenses under section 174....more
U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules, which could substantially increase the tax owed on exit for U.S....more
1/9/2020
/ Business Taxes ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Fair Market Value ,
Foreign Corporations ,
GILTI tax ,
Income Taxes ,
Investors ,
IRS ,
Partnerships ,
Passive Investments ,
PFIC ,
Proposed Regulation ,
Startups ,
Subpart F ,
Venture Capital