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Foreign Subsidiaries Controlled Foreign Corporations Subsidiaries

Miller Canfield

Can Legislative History Restore a Repealed IRC Provision?

Miller Canfield on

Altria Group, Inc. v. United States, a federal income tax case pending in federal district court in Virginia, shows the importance of laying groundwork for litigation long before a complaint is filed. At issue is a difficult...more

Dechert LLP

IRS Releases Final Tax Regulations on Imputed Income from Subsidiaries and Other Controlled Foreign Corporations

Dechert LLP on

On March 18, 2019, the U.S. Department of the Treasury and the Internal Revenue Service issued final tax regulations for registered investment funds that are taxed as regulated investment companies (“RICs”) and that invest in...more

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