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Section 956

Questioning Old Regulations

August 1, 2019 By Jasper L. (Jack) Cummings, Jr.

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

Filed Under: Federal Tax Advisory Tagged With: Section 951, Section 956, Subpart F, Third Circuit, Treasury

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

November 15, 2018 By Jasper L. (Jack) Cummings, Jr., Scott Harty and Daniel Reach

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

Filed Under: International Tax Advisory Tagged With: CFC, IRS, Revenue Act of 1962, Section 951, Section 956, Tax Cuts and Jobs Act, tax reform, TCJA, Treasury

Inexplicably, Section 956 Survives Tax Reform Intact

February 15, 2018 By Jasper L. (Jack) Cummings, Jr., Edward Tanenbaum and Stefanie Kavanagh

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

Filed Under: International Tax Advisory, Tax Reform Tagged With: Revenue Act of 1962, Section 956, Tax Cuts and Jobs Act, tax reform

Killing the Killer B: The Treasury and IRS Issue a Sixth Set of Rules on Killer B Transactions

December 15, 2016 By Jasper L. (Jack) Cummings, Jr. and Stefanie Kavanagh

The Treasury looks to slay Killer B transactions with its newest rules. Our International Tax Group follows the trail of glitches in the regulation.

Read the full advisory here.

Filed Under: International Tax Advisory Tagged With: Acquiring A, Advisory, CFC, E&P, Earnings and Profits, foreign corporation, international tax, IRS, Issuer A, Killer B, Notice 2014-32, Notice 2016-73, REg 1.367(b)-10, Section 301, Section 367, Section 956, stock-for-stock B, Treasury

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