The National Law Review

IRS and Treasury Issue Final IRC Section 956 Regulations that Reduce Deemed Income Inclusion for Certain Corporate U.S. Shareholders

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The National Law Review

Final IRS Regulations Sync Section 956 with TCJA Participation Exemption – Limits “Deemed Dividends” for U.S. Corporate Shareholders of CFCs

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Jurist

Treatment of Related Person Factoring Income; Certain Investments in United States Property; and Stock Redemptions Through Related Corporations

Internal Revenue Service (IRS), Treasury. Furthermore, on April 8, 2016, the Treasury Department and the IRS published in the Federal Register proposed regulations (81 FR 20588), which contain in ...