News & Analysis as of

Revenue Procedure 2016-50

Eversheds Sutherland (US) LLP

Reversing Course—Proposed Regulations Reverse IRS Ruling Position on Treatment of Income from CFCs and PFICs for RIC Qualification...

Eversheds Sutherland (US) LLP on

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

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