In case you missed it's release right before the President's Day holiday weekend, our International Tax Group addressed an election under Section 962 available to individual U.S. shareholders of certain foreign corporations to be taxed as a C corporation, which before tax reform was a rarely utilized and often forgotten tool that has recently been thrust into the spotlight due to its potential benefits.
The rise in popularity of the Section 962 election
Smith v. Commissioner, an unfavorable ruling for U.S. shareholders receiving distributions of foreign earnings subject to a Section 962 [...]Read more
The IRS gets granular on new Section 864(c)(8), created by the Tax Cuts and Jobs Act. Our International Tax Group examines the implications of the newest proposed regulations brought on by tax reform.
How Section 864(c)(8) codifies longstanding IRS principles on effectively connected income
The proposed regulations’ complex formula for deemed partnership asset sales
Application to tiered partnerships and treaties
Read the full advisory here. [...]Read more