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Final and Proposed PFIC Regulations Provide Further Guidance for Non-U.S. Insurance Companies and Their U.S. Investors

USA - December 7 2020 On December 4, 2020, the U.S. Internal Revenue Service and Department of the Treasury released final and proposed regulations relating to passive…

Daniel Altman, Laura M. Barzilai, Christian Brause, Tracy D.Williams

New IRS Rules Fix Only Collateral Damage of CFC “Downward Attribution” Changes

USA - October 3 2019 The U.S. Treasury Department (Treasury) and Internal Revenue Service (IRS) on October 1, 2019 released proposed regulations and a Revenue Procedure…

Laura M. Barzilai, Christian Brause

Proposed PFIC Regulations Released

USA - July 11 2019 On July 10, 2019, the U.S. Internal Revenue Service and Department of the Treasury released proposed regulations relating to passive foreign…

Daniel Altman, Laura M. Barzilai, Christian Brause, Tracy D.Williams

Proposed Regulations Provide Relief from GILTI and Subpart F Income Inclusions from CFCs for Private Equity Funds

USA - June 19 2019 On June 14, 2019, the U.S. Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) published proposed regulations (Proposed…

Daniel Altman, Christian Brause, Dominique Gallego, John T. Schaff, Noam M. Waltuch

IRS Removes Debt Documentation Regulations

USA - September 21 2018 On September 21, 2018, in connection with President Donald Trump’s Executive Order 13789 instructing the Secretary of the Treasury to review…

Daniel Altman, Laura M. Barzilai, Nicholas R. Brown, Dominique Gallego, Robert M. Kreitman, John T. Schaff