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Treasury Issues Proposed Regulations Under Section 382 That Would Ease Compliance Requirements For Tracking Small Shareholder Ownership
Introduction On November 23, 2011, the Internal Revenue Service (the "IRS") issued new Proposed Regulations under Section 3821 that, if adopted and finalized, would limit the application of the Section 382 segregation rules (discussed in detail below) to public groups in...
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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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