Tag Archives: Section 956

Inexplicably, Section 956 Survives Tax Reform Intact

Written by , and
How did a section of the Internal Revenue Code destined for repeal by both the House and Senate versions of the Tax Cuts and Jobs Act survive the final Act? Our International Tax Group examines the future application of Section 956 in the wake of the new tax regime. Section 956’s 50-plus-year history The House and Senate versions Scope of application Read the full advisory here. [...]Read more

Killing the Killer B: The Treasury and IRS Issue a Sixth Set of Rules on Killer B Transactions

Written by and

The Treasury looks to slay Killer B transactions with its newest rules. Our International Tax Group follows the trail of glitches in the regulation.

Read the full advisory here.