In response to the Third Circuit's SIH Partners v. Commissioner ruling, our Federal Tax Group reflects on the decision and suggests taking a second look at old Treasury regulations that might not survive judicial scrutiny. The court worked hard to save Section 956 How much deference will a court give Treasury? For example: Section 951 Read the full advisory here. [...]Read more
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
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
The Treasury looks to slay Killer B transactions with its newest rules. Our International Tax Group follows the trail of glitches in the regulation.