Tag Archives: IRS

Proposed regulations eliminate major US tax impediments to utilizing foreign subsidiaries for credit support

By: Tom Geraghty, Michael Greenberg and Zachary Nolan On October 31, 2018, the US Treasury and the IRS released proposed regulations under Section 956 (the Proposed Regulations), which substantially limit the application of Section 956’s “deemed dividend” rules to US corporations.1 This limitation on the application of Section 956 potentially increases the ability for US corporate borrowers … Continue Reading

Avoid misclassification quagmires by understanding differences between contractors and employees in the US

Classification missteps can translate to significant legal and economic risk for businesses.  Our colleague Isabel A. Crosby discusses how the first and critical step in the hiring process in the US is the determination of the worker’s status as an employee or independent contractor when engaging a worker to perform paid work services. To learn more about … Continue Reading
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