This is a recent addition to my ‘International Tax Update’ manual: OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) Base...

IRS issues proposed regulations on withholding for foreign investors in qualified opportunity zone funds (NPRM REG-121095-19; Apr. 14,...

Draft 2021 Schedules K2 and K3 Released (IR-2021-98; April 30, 2021) The IRS has released draft Schedules K-2 and K-3 for the Forms 1065,...

Form 8832, ‘Entity Classification Election’ Eligible foreign and domestic entities use the Form 8832 to elect how it will be classified...

The TCJA repealed §958(b)(4) which stated that the ‘downward attribution’ rule of 318(a)(3) was not to be applied so as to consider a US...