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386 results found

Article

Paul Hastings LLP | USA | 11 Nov 2016

Final and Proposed Regulations Address U.S. Property Held by CFCs in Transactions Involving Partnerships

On November 3, 2016, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued final regulations under sections

Article

Eversheds Sutherland (US) LLP | USA | 3 Oct 2016

Reversing CourseProposed Regulations Reverse IRS Ruling Position on Treatment of Income from CFCs and PFICs for RIC Qualification Purposes

On September 27, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (REG-123600-16) (the

Article

Morgan Lewis | USA | 30 Sep 2016

IRS and Treasury Issue Guidance Regarding CFC and PFIC Investments by RICs

The recently proposed regulations, if finalized, would govern the treatment of RICs' income inclusions in respect of CFCs and PFICs for purposes of

Article

Bilzin Sumberg | USA | 26 Aug 2016

Cancellation of CFC Loans to US Shareholders - Should the Service Get a Second Bite at the Apple?

The Service generally has three years after a return is filed to assess any tax due for that year. There are a number of exceptions to this general

Article

Lee and Li Attorneys at Law | OECD, China | 26 Aug 2016

BEPS-related Tax Law - CFC and PEM Rules

Anti-tax-avoidance has become an important issue among tax authorities in almost every jurisdiction, not least of all in the Republic of China. The

Article

Beveridge & Diamond PC | USA | 27 Jun 2016

EPA’s Enforcement Focus on Refrigerants Continues With Another Multi-million Dollar Settlement

The U.S. Environmental Protection Agency (“EPA” or “Agency”) continues its enforcement focus on commercial refrigerant leaks from major retailers

Article

CMS Russia | Russia | 29 Feb 2016

Update on Russian CFC rules: further tightening of the de-offshorisation policy or a positive development for taxpayers?

On 15 February 2016, the Russian President signed Federal Law No. 32-FZ (the "Law") introducing a series of amendments aimed at removing some...

Article

Cliffe Dekker Hofmeyr | South Africa | 24 Feb 2016

Adjustment for foreign group losses to be removed from the CFC high-tax exemption calculation

The controlled foreign company (CFC) provisions contained in s9D of the Income Tax Act were amended with effect from 1 January 2008 (applicable to

Article

Baker McKenzie | Russia | 18 Feb 2016

A New Set of Amendments to the Russian CFC and Beneficial Ownership Rules

On February 15, 2016, the President of the Russian Federation signed Federal Law No. 32-FZ "On Amendments to the First and Second Parts of the

Article

Dentons | Russia | 15 Feb 2016

New amendments to the “CFC rules” adopted

On February 15, 2016 the President of the Russian Federation signed Federal Law No. 32-FZ on Amendments to Parts One and Two of the Russian

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