Proposed regulations regarding domestic reverse hybrid entities

Article Abstract:

The authors discuss IRS regulations proposed under IRC section 894 regarding the taxation of domestic reverse hybrid entities.

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Cross-border hybrid instruments

Article Abstract:

The authors discuss tax issues regarding cross-border hybrid instruments, and congressional and Treasury Dept attempts to curb their use.

Foreign investments

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Characterization and foreign tax credit issues in certain post-closing integration transactions

Article Abstract:

U.S. multinationals acquiring other multinationals often attempt to reorganize to eliminate redundancies. Often this is done by liquidating entities of the acquired corporation. The US tax consequences of such transactions are discussed.

Legal issues & crime, Government regulation (cont), Government regulation, Taxes, Legal/Government Regulation, Multinational Corporations, Laws, regulations and rules, Acquisitions and mergers, Corporate reorganizations, Foreign tax credit, Liquidation

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