Finally finalized: IRS issues final regulations under Code sec. 367(b)

Article Abstract:

The authors provide specific and detailed tax law information concerning IRS final regulations under IRC section 367(b) which concern section 1248. The regulations provide guidance on U.S. shareholder taxation and U.S. corporation tax treatment related to controlled foreign corporations and foreign corporations.

Tax Law, Public Finance Activities, International, Profit, Accounting and auditing, Profits, Affiliated corporations, Stockholders, Controlled foreign corporations

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Notice 2000-20: branch currency translation gains and losses

Article Abstract:

The authors discuss IRS regulations under IRC section 987 regarding the calculation of gains or losses for branch corporations in their "functional currency".

Foreign exchange, Branches (Business enterprises)

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New proposed code sec. 367(b) regulations govern the carryout of tax attributes in reorganizations involving foreign corporations

Article Abstract:

The authors discuss the IRS' proposed regulations under IRC section 367(b), which govern carryover tax attributes for foreign corporations involved in reorganizations.

Corporate reorganizations, Basis (Taxation)

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