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Tax Talks Blog

Articles: 1-10 of 96

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…

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…

Proposed Regulations Provide Clarity for Qualified Foreign Pension Fund Exception

USA - July 3 2019 On June 7, 2019, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) released proposed Treasury Regulations under…

Upper Tribunal Rules in Favour of Taxpayer in Tax Residence Case

United Kingdom - June 19 2019 As we reported in our August 2017 UK Tax Round-Up [https://www.proskauer.com/newsletter/uk-tax-round-up-august-2017],…

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…

Section 1446(f) Proposed Regulations: Key Guidance on Partnership Interest Transfers by Non-U.S. Persons

USA - May 22 2019 On May 13, 2019, the U.S. Internal Revenue Service (“IRS”) and Treasury Department published proposed regulations providing guidance on the rules…

Are fixed rate preference shares “ordinary share capital” for entrepreneurs’ relief - more or less certainty?

United Kingdom, USA - May 7 2019 There has been another development on the tricky but important subject of whether the rights attaching to preference shares mean that they are or are…

The Second Set of Proposed Opportunity Zone Regulations

USA - April 30 2019 On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set…

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…

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…