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Following the BEAT: IRS Issues Proposed Regulations on Application of Base Erosion and Anti-Abuse Tax

USA - January 14 2019 Aggregate corporations related by 50 common ownership, including foreign corporations to the extent of their effectively connected...

Jared W. Grimley, Elena Romanova, Michael J. Rowe, Jiyeon Lee-Lim.

New Proposed Treasury Regulations May Eliminate Adverse Tax Consequences on Use of Foreign Credit Support for US Corporate Borrowings

USA - November 5 2018 On October 31, 2018, the US Treasury and Internal Revenue Service issued proposed regulations...

Jocelyn F. Noll, Elena Romanova, Aaron M. Bernstein, Joseph M. Kronsnoble, Jiyeon Lee-Lim, Y. Bora Bozkurt.

Cross-Border Financing: Taxpayer Wins on Characterization of Intercompany Debt Transaction

USA - August 14 2018 Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established...

Jared W. Grimley, Stephen N. Shashy, Joseph M. Kronsnoble, Miriam L. Fisher, Brian C. McManus.

Cross-Border M&A: Putting the Recently Finalized US Inversion Regulations into Context Following US Tax Reform

USA - July 26 2018 On July 11, 2018, the US Department of the Treasury (Treasury) and the Internal Revenue Service (the IRS) issued final regulations (the Regulations)...

Laurence J. Stein, Jared W. Grimley, Sean M. FitzGerald.

IRS Launches New Compliance Campaigns on Repatriation of Foreign Earnings and Virtual Currency

USA - July 13 2018 LB&I has announced compliance initiatives regarding the Section 965 Transition Tax, Repatriation via Foreign Triangular Reorganizations, and Virtual...

Jason B. Grover, Andrew C. Strelka, Shannon Fiedler, Jean A. Pawlow, Stephen N. Shashy, Miriam L. Fisher, Brian C. McManus.