The US Treasury and the Internal Revenue Service issued proposed regulations last Thursday providing guidance for determining a US shareholder’s pro rata share of income for controlled foreign corporations (CFCs) under the subpart F rules. The proposed regulations provide detailed rules on distributions of earnings when a CFC has multiple classes of stock. When issued in final form the regulations will be effective for tax years beginning January 1 2005.
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The deal establishes Ryan’s property tax presence in Scotland and expands its ability to serve clients with complex commercial property portfolios across the UK, the firm said
Trump announced he will cut tariffs after India agreed to stop buying Russian oil; in other news, more than 300 delegates gathered at the OECD to discuss VAT fraud prevention
Taxpayers should support the MAP process by sharing accurate information early on and maintaining open communication with the competent authorities, the OECD also said
The Fortune 150 energy multinational is among more than 12 companies participating in the initiative, which ‘helps tax teams put generative AI to work’
The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals
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There is a shocking discrepancy between professional services firms’ parental leave packages. Those that fail to get with the times risk losing out in the war for talent