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.