On October 31, 2018, the Internal Revenue Service (IRS) and US Department of the Treasury (Treasury) released proposed regulations (REG-114540-18) (the Proposed Regulations) that would prevent, in many cases, income inclusions for corporate US shareholders of controlled foreign corporations (CFCs) under section 956. As a result, among other considerations, the Proposed Regulations could significantly expand the ability of corporate US affiliates to benefit from credit support of CFCs.
Proposed Regulations under Section 956 Provide Benefits for Corporate Taxpayers
Bradford E. LaBonteBradford E. LaBonte focuses his practice on US and international tax matters. He advises multinational corporations and investment funds on matters related to cross-border mergers and acquisitions, cash repatriation, controlled foreign corporation (CFC) and passive foreign investment company (PFIC) regimes, financial instrument classification, US trade or business determinations, US income tax treaty qualification and planning, and US withholding tax issues. Read Bradford LaBonte's full bio.
Lowell D. YoderLowell D. Yoder focuses his practice on cross-border mergers and acquisitions, global tax planning and international tax controversies, representing high-tech, pharmaceutical, e-commerce, financial, consumer and industrial companies. He advises on tax-efficient structuring of cross-border acquisitions, dispositions, financings, internal reorganizations and joint ventures, as well as tax-beneficial planning for intangible holding companies, global supply chains and multi-jurisdictional service arrangements. Lowell also represents clients before the Internal Revenue Service (IRS), handling audits and obtaining tax rulings. He works with an extensive network of lawyers worldwide, developing tax-favorable transactional and operational cross-border structures. Lowell is the global head of McDermott's Tax Practice. Read Lowell Yoder's full bio.
Timothy S. ShumanTimothy (Tim) S. Shuman focuses his practice on corporate and international tax matters for US and non-US multinationals, with particular emphasis on domestic and cross-border acquisitions, dispositions, restructurings and liquidations. He has extensive experience in structuring spin-offs and tax-free reorganizations involving publicly traded and privately held companies, and regularly represents clients in obtaining private letter rulings and other guidance from the Internal Revenue Service (IRS). He also works on tax issues involving regulated investment companies. Read Tim Shuman's full bio.
Related Posts
BLOG EDITORS
STAY CONNECTED
TOPICS
ARCHIVES
