Matthew Brown

A&O Shearman

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Notice 2024-16 Announces Limited Guidance Under Section 961(c)

On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the...more

1/8/2024 / Corporate Taxes , Double Taxation , Federal Taxes , Foreign Corporations , International Tax Issues , IRS , Proposed Regulation , U.S. Treasury

Notice 2024-10 Provides Interim Guidance on the Application of the CAMT with Respect to Controlled Foreign Corporations and...

On December 15, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) issued Notice 2024-10 (the “Notice”), providing much needed interim guidance on the application of the Corporate...more

12/26/2023 / Business Taxes , CFC , Corporate Taxes , Foreign Corporations , Foreign Investment , IRS , Shareholders , U.S. Treasury

Notice 2023-80 Announces FTC and DCL Guidance For Pillar Two Taxes

On December 11, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2023-80 (the “Notice”), announcing their intention to issue proposed regulations that will address...more

12/18/2023 / Corporate Taxes , Foreign Tax Credits , GILTI tax , International Tax Issues , IRS , U.S. Treasury

Funding Rule Under Notice 2023-2 Expands the Scope of the Stock Buyback Excise Tax to Repurchases of Stock of Many Foreign...

Notice 2023-2 (the “Notice”) provides guidance regarding the scope and application of the excise tax on buybacks of stock of publicly traded domestic corporations and certain publicly traded foreign corporations (the “Excise...more

4/4/2023 / Business Taxes , Corporate Taxes , Excise Tax , Internal Revenue Code (IRC) , IRS , Tax Planning , Tax Reform

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