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,
The U.S. Treasury Department ("Treasury") proposed regulations relating to the new Opportunity Zone tax incentive. The tax incentive is intended to encourage investments in economically distressed communities by allowing taxpayers to defer capital gains tax if they reinvest within 180 days in "qualified opportunity funds" ("QOFs"), which are generally required to maintain at least 90 percent of their assets in "qualifying opportunity zone property." In addition, an investor who holds a QOF investment for at least 10 years may qualify to increase its basis to the fair market value of the
The Internal Revenue Service's final regulations on the centralized partnership audit regime were published in the Federal Register.
The IRS will delay the effective/applicability date of certain rules in the final Section 871(m) regulations, and extend parts of the phase-in period by one year.