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
On November 12, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published proposed regulations (REG-101657-20) (the “2020 Proposed Regulations”) in the Federal Register that contain a...more
On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (TD 9922) (the 2020 Final Regulations) and related proposed regulations (REG-101657-20) (the...more
On July 23, 2020, the US Department of the Treasury and the Internal Revenue Service (IRS) published final regulations addressing the global intangible low-taxed income (GILTI) high-tax exclusion (85 FR 44620) (the “Final...more
8/10/2020
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