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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

Federal Tax Advisory: New Spin-Off Regulations Proposed

August 1, 2016 By Jasper L. (Jack) Cummings, Jr.

It could have been worse. Our Federal Tax Group examines the good news and bad news of the Treasury’s latest reinterpretation of Section 355.

Click here to read the full advisory.

Filed Under: Federal Tax Advisory Tagged With: active trade, ATB, business assets, device factor, IRS, nondevice factors, Reg. Section1.355-2(d), safe harbor, Section 355, Treasury

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