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IRS Releases Memorandum Regarding Advance Payments of Section 367(d) Inclusions

On September 23, 2022, the Internal Revenue Service (IRS) released a memorandum (AM 2022-003) concluding that taxpayers cannot make advance payments of section 367(d) inclusions except in the limited situation in which the US...more

Benefits of a Section 338 Election to a US Buyer of CFC Stock

The 2017 Tax Act significantly increased the benefits of a section 338(g) election for a domestic corporate purchaser of stock in a controlled foreign corporation (CFC). If an election is made, the Buyer is treated as...more

Focus on Tax Strategies & Developments - October 2015

Regulatory Developments Under ยง 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

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