Reg. section 1.904-4(a)-(q) governs the separate application of the section 904 foreign tax credit limitation to categories of income. Published January 2, T.D. 9959 added guidance to the rules in reg ...
More than 25 years ago, effective January 1, 1997, Treasury issued what have been called the “Check-the-Box” regulations (the “Regulations”). 1 The Regulations ended decades of battles between ...
Be wary: The US Department of the Treasury’s proposed disregarded payment loss (DPL) regulations lay surprising new traps for multinational taxpayers – and those ensnared are unlikely to see what’s ...
In temporary and proposed regulations issued earlier this month, the Treasury Department clarified the self-employment tax treatment for partners of a partnership that own a disregarded entity. Let me ...
On Dec. 12, 2016, the Treasury Department and the Internal Revenue Service announced final regulations (issued in proposed form on May 5, 2016) requiring domestic disregarded entities with foreign ...
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