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
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
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