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Article

Fox Rothschild LLP | USA | 1 Aug 2011

New Final Regulations issued by Treasury and Internal Revenue Service with respect to the treatment of certain intercompany gain with respect to stock owned by members of a consolidated group: TD 9515, 2011-14 IRB 599

Several years ago, the Service published Temp. Reg. 1.1502-13T along with Proposed Regulations which addressed the tax consequences with respect to intercompany gains of subsidiary stock that was part of a consolidated group of corporations

Article

Fox Rothschild LLP | USA, Japan | 19 Jun 2011

Representatives of Japan and the United States commence negotiations on amendments to the U.S.-Japan income tax treaty

The U.S. Department of the Treasury having announced on June 2, 2011 that it planned to begin formal negotiation of amendments to the existing bilateral income tax treaty with Japan, which Treaty was entered into force in 2004, commenced negotiations on June 8-10 in Washington, D.C.

Article

Fox Rothschild LLP | USA | 23 May 2011

New final and temporary regulations on treatment of certain intercompany gains with respect to stock owned by members of a consolidated group of corporations

On March 4, 2011, the Treasury issued T.D.9515, containing final regulations on the treatment of certain intercompany gains with respect to stock owned by members of a consolidated group.

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