Tag Archives: Revenue Act of 1962

Plot Twist – Proposed Regulations Mean Section 956 Did Not Actually Survive Tax Reform Intact

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Our International Tax Group takes stock of new proposed regulations that try to keep Section 956 relevant despite the Tax Cuts and Jobs Act. Many were left scratching their heads “A result directly at odds with the manifest purpose of Section 956” Impact of the proposed regulations Read the full advisory here. [...]Read more

Inexplicably, Section 956 Survives Tax Reform Intact

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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