Old Law, New Tricks: Long-Awaited PFIC Guidance Proposed
Our International Tax Group highlights new guidance on fundamental issues and points out a few sources of potential headache for taxpayers in response to the IRS and Treasury proposing the most significant regulations on passive foreign investment companies (PFICs) in nearly 30 years.
Clarifications for the Income and Asset Tests
Updates to the PFIC exceptions and look-through rules
PFIC stock attribution
Read the full advisory here. [...]Read more
Book Value Sales
Our Federal Tax Group explores how affiliates selling property to each other at book value could cause more problems than it solves.
- Book value
- Fair market value
- The tax consequences
Read the full advisory here.
Federal Tax Advisory: Stock Dividend Foot Faults
Beware of the unexpected application of Section 305 to your stock distributions. Our Federal Tax Group serves up examples of useful tools to use.
Read the full advisory by clicking here.