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IRS Proposes Regulations Under Section 892 Regarding Taxation Of Foreign Government Entities
The Internal Revenue Service (IRS) has issued proposed regulations under Section 892 of the Internal Revenue Code (available here) that generally provide favorable clarifications and modifications of the rules governing eligibility for the Section 892 tax exemption of a controlled entity of a...
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The IRS Proposes New Rules Under Section 892 That May Simplify Foreign Governments’ Investments In The United States, Including In Private Equity Funds
On November 2, 2011, the Internal Revenue Service (the “IRS”) issued proposed regulations under section 892[1] (the “Proposed Regulations”) that provide guidance to foreign governments and their controlled entities for making investments in the U.S. The Proposed...
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IRS Releases Timeline For Implementing FATCA, Including Delaying The Deadline Until 2014 For Foreign Financial Institutions' Compliance With Certain Provisions
On July 14, 2011, the Internal Revenue Service issued Notice 2011-531announcing plans to phase in the requirements of the Foreign Account Tax Compliance Act ("FATCA"), which targets noncompliance by U.S. taxpayers holding foreign accounts. The Notice addresses certain compliance,...
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