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Proposed Regulations on Built-in Gains and Losses under Section 382(h)

USA - September 19 2019 On September 10, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the...

Muhyung (Aaron) Lee, Martin T Hamilton, Alan P Parnes.

State Tax on Trust Income Based Solely on In-State Residence of Beneficiaries Found Unconstitutional

USA - July 3 2019 On June 21, 2019, the United States Supreme Court decided North Carolina Dept. Of Revenue v. Kimberly Rice Kaestner 1992 Family Trust (hereinafter...

David S. Miller, Christine N. Sherman, Mitchell M Gaswirth, Stuart L Rosow.

Final IRS Regulations Sync Section 956 with TCJA Participation Exemption - Limits “Deemed Dividends” for U.S. Corporate Shareholders of CFCs

USA - May 30 2019 Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned...

David S. Miller, Malcolm Hochenberg, Jeremy Naylor, Amanda H Nussbaum, Martin T Hamilton.

Players, Staff and Draft Picks May be Traded Tax-Free Under New Safe Harbor

USA - April 25 2019 On April 11, 2019, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2019-18, creating a safe harbor that allows professional sports...

Malcolm Hochenberg, Christine N. Sherman, Jon H. Oram, Amanda H Nussbaum, Alan P Parnes.

Proposed FDII Regulations under Section 250

USA - April 22 2019 On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed...

David S. Miller, Sean M. Webb, Elizabeth Johnston Wytock, Amanda H Nussbaum, Stuart L Rosow.