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proposed regulations

Down the Rabbit Hole: Guidance Addressing Downward Attribution After Repeal of Section 958(b)(4)

October 15, 2019 By Edward Tanenbaum and Daniel Reach

The IRS released Proposed Regulations and a Revenue Procedure addressing the Tax Cuts and Jobs Act’s repeal of Section 958(b)(4). Our International Tax Group explores how this guidance affects numerous provisions of the Code. Downward attribution beyond Subpart F, GILTI, and Section 965 Silence on the portfolio interest exemption Safe harbors and eased reporting requirements Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: 958(b)(4), GILTI, IRS, portfolio interest exemption, proposed regulations, Revenue Procedure, safe harbor, section 965, Subpart F, Tax Cuts and Jobs Act, tax refrom

Proposed Sec. 367 Regs Say Goodbye to Goodwill Exception

November 23, 2015 By Heather Ripley

Citing aggressive taxpayer positions, recently proposed regulations do away with the foreign goodwill exception to gain or income recognition for outbound transfers under Section 367. The rules also restrict the type of property eligible for the active business exception. Reasons for Change Per the preamble, taxpayers interpret Section 367 and the regulations in one of two ways when claiming favorable treatment of foreign goodwill and going concern value. One interpretation argues that goodwill and going concern value are not IP within the meaning of Section 936(h)(3)(B) and thus not subject [...]Read more

Filed Under: International - Corporate Tax Planning, International - Outbound, International - Transfer Pricing, International Tax Advisory, Mergers and Acquisitions - International Tagged With: active business exception, Corporate Tax Planning, foreign corporation, foreign goodwill exception, goodwill, intangible property, IRS, outbound, proposed regulations, Section 367, section 482, temporary regulations, transfer pricing

Letter Ruling Addresses C Corporation’s Conversion to a REIT

February 3, 2015 By Jasper L. (Jack) Cummings, Jr.

The IRS recently released the letter ruling (PLR 201503010) that was likely issued to Iron Mountain, a US multinational document storage company, on its conversion to a REIT. The taxpayer in the ruling proposed retaining its leases and ownership interests in warehouse-like buildings and racking structures therein in the corporation that would elect REIT status and moving its document storage activities into taxable REIT subsidiaries. The letter ruling contained more than a dozen separate rulings, evincing the complexity of transitioning from a C corporation to a REIT, particularly when [...]Read more

Filed Under: Corporate - Federal, Federal Tax Advisory, RICs, REITs and other Special Entities Tagged With: change of accounting method, conversion to REIT, E&P, IRS letter ruling, proposed regulations, real property, REIT, REIT subsidiary, section 481, section 856

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