This article explores key recent developments that could impact proposed regulations as they become final.
FOREIGN INCOME & TAXPAYERS
January 2017 - The Tax Adviser
corporations & shareholders
How to Document a Tax-Free D Reorganization With a Split-Off
A taxpayer that treats a split-off transaction
as a tax-free D reorganization must be able to
prove to the IRS that the transaction meets all requirements.
corporations & shareholders
Sec. 385 Regulations Impose Intergroup Debt Requirements
The final and temporary regulations substantially revised the proposed regulations, reducing their scope.