Tag Archives: Pallav Raghuvanshi

Proposed Regulations for Qualified Foreign Pension Funds that are Exempt from U.S. Tax on Disposition of U.S. Real Property Interests

The Foreign Investment in Real Property Tax Act of 1980, as amended (FIRPTA), imposes tax on gain realized on disposition by nonresident alien individuals or foreign corporations (non-U.S. persons) of a U.S. real property interests (USRPI) by treating such gain as effectively connected with the conduct of a U.S. trade or business by such non-U.S. … Continue Reading

IRS and Treasury Issue Final IRC Section 956 Regulations that Reduce Deemed Income Inclusion for Certain Corporate U.S. Shareholders

On May 23, 2019, the Internal Revenue Service (IRS) and the Treasury Department issued final regulations (the Final Section 956 Regulations) intended to mitigate the impact of Section 956 of the Internal Revenue Code (the Code) for certain domestic corporations. Consistent with the proposed regulations issued in November 2018 (see previous GT Alert here), the Final … Continue Reading

Proposed Regulations on the Interest Deduction Limitation Under Section 163(j) of the Internal Revenue Code

On Nov. 26, 2018, the IRS issued proposed regulations under the Internal Revenue Code (IRC) § 163(j) enacted by the Tax Cuts and Jobs Act of 2017 (the Proposed Regulations). Generally, IRC § 163(j) limits certain taxpayers’ business interest expense deduction to the sum of (i) the taxpayer’s current year business interest income, (ii) 30 … Continue Reading

Token Issuers and Purchasers, Beware: The IRS May Tax Each Time Tokens are Used

Many blockchain companies are using a largely unregulated means of raising funds, commonly known as an initial coin offering (ICO).[1]  An ICO consists of the issuance of a newly generated cryptocurrency (generally referred to as a token) that runs on blockchain technology, in exchange for fiat currency (such as U.S. dollars) or other cryptocurrencies like … Continue Reading
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