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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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UK Business Environment: Positive And Forward-Looking
Editor: Please discuss the current economic and business environment in the UK. Lopez: Despite the current global economic turmoil and unique economic challenges currently faced by Europe, the UK business environment remains positive, forward-looking and open for business. The UK government is...
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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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