On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on:
..Transfer pricing for “captive” services...more
4/29/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
FATCA ,
Filing Requirements ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
OECD ,
Offshore Banks ,
OVDP ,
Related Parties ,
Transfer Pricing
On March 19, 2019, the Internal Revenue Service (IRS) and Treasury Department (Treasury) issued final regulations (T.D. 9851) (Final Regulations) under section 851 addressing the income test applicable to regulated investment...more
3/25/2019
/ Controlled Foreign Corporations ,
Final Rules ,
Internal Revenue Code (IRC) ,
IRS ,
Passive Foreign Investment Company ,
Public Comment ,
Registered Investment Companies (RICs) ,
Rulemaking Process ,
Securities ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
On August 1, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations, which were published in the Federal Register on August 9, 2018 (Proposed Regulations),...more
On September 27, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (REG-123600-16) (the Proposed Regulations) under section 851 addressing the income test applicable...more