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High Line on the Hybrid Rules
Lee Sheppard looks at the state of withholding on payments to hybrid entities and payments on hybrid instruments after the recent release of guidance by the U.S. Treasury.
By Lee A. Sheppard
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New Regs Ease Double Counting and Mismatches
Carrie Brandon Elliot describes how the proposed regs related to section 163(j) seek to help taxpayers avoid mismatches and double-counting.
By Carrie Brandon Elliot
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Proposed Regs Target Old CFC Attribution Issues, Avoid New Ones
Treasury and the IRS have proposed regulations restricting the scope of downward attribution of stock in controlled foreign corporations without addressing one of the Tax Cuts and Jobs Act’s controversial and seemingly unintended consequences.
By Ryan Finley
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