Daily Tax Update - November 2, 2016: IRS Issues Final Regulations on Controlled Foreign Corporations

IRS Issues Final Regulations on Controlled Foreign Corporations:  The IRS and Treasury issued final regulations regarding the treatment of property held by a controlled foreign corporation (CFC) as United States property in connection with certain loan or guarantee transactions involving partnerships.  In addition, the final regulations provide rules for determining whether a CFC is considered to derive rents and royalties in the active conduct of a trade or business for purposes of determining foreign personal holding company income, as well as rules for determining whether a CFC holds United States property as a result of certain related party factoring transactions.  The rules finalize proposed regulations issued in 2015.  The rules regarding factoring transactions also partially finalize proposed regulations issued in 1988.

DTU In Depth - Election Update 

One Week Until the 2016 Election - Public Policy Implications:  Today marks the beginning of the last week of the 2016 presidential election cycle.  About 26 million people have already voted through early voting.  As we have seen over the last 18 months, policy positions and personal character issues have both played an important role in persuading voters who they should support when they cast their votes.  Click here to read more.