Tax structuring under the previous regime -
Prior to the issuance of the final regulations described below, under Section 956 of the Internal Revenue Code of 1986 and its related Treasury Regulations, for U.S. tax...more
6/12/2019
/ Borrowers ,
Contract Terms ,
Controlled Foreign Corporations ,
Corporate Liability ,
Credit Agreements ,
Dividends ,
Foreign Subsidiaries ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Parent Corporation ,
Proposed Regulation ,
Section 956 ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
Tax Structuring
Until the issuance of the Proposed Regulations described below, under Section 956 of the Internal Revenue Code of 1986 (IRC) and Treasury Regulations thereunder, deemed dividends were potentially created when a U.S. borrower...more
11/15/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Credit Agreements ,
Dividends ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Section 956 ,
Tax Exemptions ,
Tax Planning ,
Taxation ,
U.S. Treasury