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IRS announces rules on transfers to foreign partnerships

USA - August 17 2015 On August 6, 2015, the IRS issued Notice 2015-54 (the Notice), describing regulations under Section 721(c) meant to ensure that gain is recognized…

Andy Immerman, Heather Ripley.

U.S. Treasury proposes changes to U.S. Model Income Tax Treaty

USA - July 15 2015 The U.S. Treasury recently proposed a number of major changes to the U.S. Model Income Tax Treaty (the "U.S. Model"), last updated in 2006. Suggested…

Heather Ripley.

Final anti-inversion regulations keep strict 25 percent tests for substantial business activities

USA - June 15 2015 Earlier this month, the IRS and U.S. Treasury released final regulations under the anti-inversion provisions of Section 7874 (T.D. 9720). The final…

Heather Ripley.

IRS to limit credits and refunds for withheld taxes to amounts deposited by withholding agents

USA - May 15 2015 In Notice 2015-10 (the "Notice"), the IRS announced that it and the Treasury will issue regulations to limit credits or refunds for certain…

Heather Ripley.

Timing may be everything for foreign tax credit-related refund claims

USA - April 15 2015 The procedural aspects of foreign tax credit carrybacks have received some press that highlights the significance of the statute of limitations…

Heather Ripley.