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Treasury Would Overhaul 2016 Regulatory Guidance

October 16, 2017 By Edward Tanenbaum and Heather Ripley

With tax reform on the horizon, Treasury takes aim at three sets of regulations with clear cross-border implications. Our International Tax Group explains the department’s recommendations to scrap much of Section 385 and overhaul Sections 367 and 987.

  • Revoking the Section 385 documentation rules
  • Expanding the active business exception to foreign goodwill under Section 367
  • Deferring transition rules under Section 987 to 2019

Read the full advisory here.

Filed Under: International Tax Advisory Tagged With: business exception to foreign goodwill, deferred transition rules, Department of Treasury, foreign goodwill, Section 367, Section 385, section 987, tax reform, Treasury, Treasury Department

About Edward Tanenbaum

Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.

[Read Bio]

About Heather Ripley

Heather Ripley is an associate in the firm’s Federal & International Tax Group. Her practice focuses on federal and international tax services for a range of clients, including domestic and international business entities and individuals.

[Read Bio]

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