June 2019 - Heckler and O Keefe CPAS

Proposed Regulations Issued on Withholding on Foreign Partner’s Disposition of Partnership Interest

Jun 1, 2019 | International

Highly anticipated proposed regulations have been issued on the withholding required with respect to the disposition of certain partnership interests. The proposed regulations affect certain foreign persons that recognize gain or loss on the disposition of an interest...

Proposed Regulations Issued on CFC Related Person Rules and Active Trade or Business Exception

Jun 1, 2019 | Taxes

Proposed regulations provide rules on the attribution of ownership of stock or other interests for determining whether a person is a related person with respect to a controlled foreign corporation (CFC) under the foreign base company sales income rules. The proposed...

Final Regulations Issued on Recognition and Deferral of Code Sec. 987 Gain or Loss

Jun 1, 2019 | Taxes

Final regulations have been issued on transactions of U.S. taxpayers that have qualified business units (QBUs) with functional currency other than the U.S. dollar. Specifically, the final regulations: cover combinations and separations of QBUs subject to Code Sec....

Proposed Regulations Issued on Withholding on Foreign Partner’s Disposition of Partnership Interest

Proposed Regulations Issued on CFC Related Person Rules and Active Trade or Business Exception

Final Regulations Issued on Recognition and Deferral of Code Sec. 987 Gain or Loss

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