IRS Releases Final Regulations under Section 6050Y
Posted on Oct 28, 2019 in Insurance Tax
The IRS has issued final regulations under section 6050Y, which was added by the TCJA. Generally, section 6050Y requires information reporting with respect to certain life insurance contract transactions, such as payments of reportable death benefits. The final regulations detail the reporting requirements, such as the manner of reporting and the required timing of such reporting....
Proposed Regulations and New Revenue Procedure Address the Repeal of Section 958(b)(4)
Posted on Oct 1, 2019 in International Tax
Treasury and the IRS have released proposed regulations and a revenue procedure addressing the repeal of section 958(b)(4). Prior to its repeal by the Tax Cuts and Jobs Act, section 958(b)(4) prevented downward attribution from a foreign person for purposes of determining whether a foreign entity was a controlled foreign corporation under section 957. The proposed regulations address...