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The U.S. Treasury Department and the IRS proposed regulations that affect certain U.S. corporations that own, or are treated as owning, stock in foreign corporations. The proposed regulations would limit the circumstances under which a "deemed repatriation" of the earnings of a controlled foreign corporation (a "CFC") under Internal Revenue Code Section 956 ("IRC Section 965") would be taxable to a corporate 10-percent U.S. shareholder. Under IRC Section 956, a CFC's previously untaxed earnings may be taxable to a 10-percent U.S. shareholder if: (i) the CFC guarantees the shareholder's debt,