News & Analysis as of

U.S. Treasury › Proposed Regulation › Tax Rates

A&O Shearman

Proposed dual consolidated loss regulations would disallow U.S. tax use of foreign losses viewed as reducing Pillar Two tax...

A&O Shearman on

On August 6, 2024, the U.S. Treasury Department (“Treasury”) issued proposed regulations under section 1503 (the “Proposed Regulations”) that address the interaction between the dual consolidated loss (“DCL”) rules and the...more

McDermott Will & Emery

Proposed Regulations Would Conform Subpart F High-Tax Exception to GILTI High-Tax Exception

McDermott Will & Emery on

On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F...more

McDermott Will & Emery

Weekly IRS Roundup December 23 – 27, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

McDermott Will & Emery

Proposed Foreign Tax Credit Regulations Provide New Rules for Allocation and Apportionment of Deductions and Creditable Foreign...

McDermott Will & Emery on

The Treasury Department and the IRS have issued highly anticipated guidance in the area of stewardship expenses and R&D expenses. The 2019 Proposed Regulations also provide extensive guidance on allocating and apportioning...more

Womble Bond Dickinson

Proposed US Tax Rules for Cloud Computing Transactions and Digital Downloads – International Implications Are a Reason to Review

Womble Bond Dickinson on

On August 9, 2019, the US Treasury Department published proposed regulations for the classification of “cloud transactions” and “transactions involving digital content” under the source of income rules of the Internal Revenue...more

Eversheds Sutherland (US) LLP

BEAT, FATCA and Insurance - proposed regulations clarify the application of the BEAT and the treatment of insurance premiums under...

Eversheds Sutherland (US) LLP on

On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued two sets of proposed regulations of importance to insurance companies. One set was the long-awaited regulations...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

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