Searching Content indexed under Finance and Banking by Martin Hamilton ordered by Published Date Descending.
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Proposed Regulations Provide Clarity For Qualified Foreign Pension Fund Exception
On June 7, 2019, the U.S. Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") released proposed Treasury regulations under Sections 897, 1445 and 1446.
United States
12 Jul 2019
Proposed FDII Regulations Under Section 250
On March 4, 2019, the Internal Revenue Service (the "IRS") and the Department of the Treasury (the "Treasury") released proposed regulations (the "Proposed Regulations")
United States
7 May 2019
"Passthrough Deduction" Regulations Finalized
The passthrough deduction provides a maximum effective rate of 29.6%.
United States
20 Mar 2019
The Proposed BEAT Regulations
On December 13, 2018, the Internal Revenue Service and the Department of the Treasury released proposed regulations with respect to the "base erosion and anti-abuse tax" under section 59A of the Internal Revenue Code.
United States
7 Jan 2019
Newly Proposed US Tax Regulations Open Possibility Of Full Credit Support From Foreign Subsidiaries
On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service (the "IRS") proposed new regulations under Section 956 of the Code.
United States
21 Nov 2018
Summary Of The Opportunity Zone Program
The Tax Cuts and Jobs Act enacted section 1400Z-2 of the Internal Revenue Code, which created the qualified opportunity zone program.
United States
14 Nov 2018
IRS And Treasury Issue Proposed Opportunity Zone Regulations
The proposed regulations answer the most pressing questions with mostly taxpayer-friendly answers.
United States
23 Oct 2018
Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements
On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding certain exceptions to the annual PFIC reporting requirements (the "PFIC Regulations").
United States
21 Jan 2017
Real Estate Investments By Qualified Foreign Pension Funds After The PATH Act
The PATH Act included a number of significant changes to the U.S. federal income tax rules related to real estate investment trusts and investments by non-U.S. investors in U.S. real estate.
United States
3 Mar 2016
Federal Appellate Court Rules That Certain Foreign Currency Options Are Subject To The Section 1256 Mark-To-Market Regime
Recently, in Wright v. Commissioner, the United States Court of Appeals for the Sixth Circuit has reopened the question of the application of Section 1256 to foreign currency options.
United States
9 Feb 2016
Significant Changes To U.S. Taxation Of REITs And Investments By Non-U.S. Investors In Real Property Under The PATH Act
On December 18, 2015, President Obama signed into law an omnibus appropriations bill which included the Protecting Americans from Tax Hikes Act of 2015.
United States
3 Feb 2016
New York Proposes First State Bitcoin Regulations
One might have thought the biggest news in the digital currency world lately was Dell announcing that it was now accepting bitcoin.
United States
25 Jul 2014
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