Proposed Regulations Issued on Source of Income for Certain Sales of Personal Property
The Treasury Department and Internal Revenue Service recently released proposed regulations (REG-100956-19) that modify the rules for determining the source
IRS to Focus on Companies That Owe Taxes on Offshore Profits
The Internal Revenue Service recently announced it would focus on companies that owe taxes on overseas profits (a Section 965 tax, or as some call it,
Reminder: Foreign-owned U.S. Disregarded Entities Face New Reporting Requirements
Until recently, disregarded entities (DREs) were typically not required to obtain an employer identification number (EIN) and generally did not have federal
IRS Issues Notice for Computing "Transition Tax"
On December 29, the Internal Revenue Service (IRS) and Treasury Department published Notice 2018-07 (Notice), providing guidance for computing the “transition