Regulations Pertaining to Mergers, Acquisitions, and Takeovers by Foreign Persons (Us Department of the Treasury Regulation) (Treas) (2018 Edition)

Regulations Pertaining to Mergers, Acquisitions, and Takeovers by Foreign Persons (Us Department of the Treasury Regulation) (Treas) (2018 Edition)
Author: The Law Library
Publisher: Independently Published
Total Pages: 74
Release: 2019-01-21
Genre: Law
ISBN: 9781794549999

The Law Library presents the complete text of the Regulations Pertaining to Mergers, Acquisitions, and Takeovers by Foreign Persons (US Department of the Treasury Regulation) (TREAS) (2018 Edition). Updated as of May 29, 2018 This Final Rule amends regulations in part 800 of 31 CFR that implement section 721 of the Defense Production Act of 1950 ("section 721"), as amended by the Foreign Investment and National Security Act of 2007, codified at 50 U.S.C. App. 2170. While the revised regulations retain many features of the prior regulations, a number of changes have been made to implement section 721, increase clarity, reflect developments in business practices over the past several years, and make additional improvements based on experiences with the prior regulations. This ebook contains: - The complete text of the Regulations Pertaining to Mergers, Acquisitions, and Takeovers by Foreign Persons (US Department of the Treasury Regulation) (TREAS) (2018 Edition) - A dynamic table of content linking to each section - A table of contents in introduction presenting a general overview of the structure

Certain Transfers of Stock Or Securities by U.S. Persons to Foreign Corporations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)

Certain Transfers of Stock Or Securities by U.S. Persons to Foreign Corporations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)
Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
Total Pages: 54
Release: 2018-11-06
Genre:
ISBN: 9781729689165

Certain Transfers of Stock or Securities by U.S. Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Certain Transfers of Stock or Securities by U.S. Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final and temporary regulations under section 367(a) of the Internal Revenue Code (Code) regarding gain recognition agreements. The final regulations are necessary to update cross-references in the current regulations. The temporary regulations are necessary to respond to comments requested in Notice 2005-74. The regulations primarily affect U.S. persons that transfer stock or securities to foreign corporations or corporations engaged in transactions that affect existing gain recognition agreements. The text of these temporary regulations also serves as the text of the proposed regulations (REG-147144-06) set forth in the notice of proposed rulemaking on this subject published elsewhere in this issue of the Federal Register. This book contains: - The complete text of the Certain Transfers of Stock or Securities by U.S. Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Treatment of Certain Transfers of Property to Foreign Corporations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)

Treatment of Certain Transfers of Property to Foreign Corporations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)
Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
Total Pages: 52
Release: 2018-11-12
Genre:
ISBN: 9781729735466

Treatment of Certain Transfers of Property to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Treatment of Certain Transfers of Property to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations relating to certain transfers of property by United States persons to foreign corporations. The final regulations affect United States persons that transfer certain property, including foreign goodwill and going concern value, to foreign corporations in nonrecognition transactions described in section 367 of the Internal Revenue Code (Code). The regulations also combine certain sections of the existing regulations under section 367(a) into a single section. This document also withdraws certain temporary regulations. This book contains: - The complete text of the Treatment of Certain Transfers of Property to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Gain Recognition Agreements with Respect to Certain Transfers of Stock Or Securities by United States Persons to Foreign Corporations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)

Gain Recognition Agreements with Respect to Certain Transfers of Stock Or Securities by United States Persons to Foreign Corporations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)
Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
Total Pages: 62
Release: 2018-11-08
Genre:
ISBN: 9781729701263

Gain Recognition Agreements with Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Gain Recognition Agreements with Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations under section 367(a) of the Internal Revenue Code (Code) concerning gain recognition agreements filed by United States persons with respect to transfers of stock or securities to foreign corporations. The regulations finalize temporary regulations published on February 5, 2007 (TD 9311). The regulations primarily affect United States persons that transfer (or have transferred) stock or securities to foreign corporations and that will enter (or have entered) into a gain recognition agreement with respect to such a transfer. This book contains: - The complete text of the Gain Recognition Agreements with Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

The Committee on Foreign Investment in the United States Cfius

The Committee on Foreign Investment in the United States Cfius
Author: Congressional Research Congressional Research Service
Publisher: Createspace Independent Publishing Platform
Total Pages: 38
Release: 2016-08-12
Genre:
ISBN: 9781539454816

The Committee on Foreign Investment in the United States (CFIUS) is comprised of nine members, two ex officio members, and other members as appointed by the President representing major departments and agencies within the federal executive branch. While the group generally has operated in relative obscurity, the proposed acquisition of commercial operations at six U.S. ports by Dubai Ports World in 2006 placed the group's operations under intense scrutiny by Members of Congress and the public. Prompted by this case, some Members of the 109th and 110th Congresses questioned the ability of Congress to exercise its oversight responsibilities given the general view that CFIUS's operations lack transparency. Other Members revisited concerns about the linkage between national security and the role of foreign investment in the U.S. economy. Some Members of Congress and others argued that the nation's security and economic concerns have changed since the September 11, 2001, terrorist attacks and that these concerns were not being reflected sufficiently in the Committee's deliberations. In addition, anecdotal evidence seemed to indicate that the CFIUS process was not market neutral. Instead, a CFIUS investigation of an investment transaction may have been perceived by some firms and by some in the financial markets as a negative factor that added to uncertainty and may have spurred firms to engage in behavior that may not have been optimal for the economy as a whole. On July 12, 2016, Senator Charles Grassley introduced S. 3161 to include the Secretary of Agriculture as a permanent member of the CFIUS and to include the national security impact of foreign investments on agricultural assets as part of the criteria the Committee uses in deciding to recommend that the President block a foreign acquisition.

Surrogate Foreign Corporations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)

Surrogate Foreign Corporations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)
Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
Total Pages: 34
Release: 2018-11-12
Genre:
ISBN: 9781729734568

Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations regarding whether a foreign corporation is treated as a surrogate foreign corporation. The final regulations affect certain domestic corporations and partnerships (and certain parties related thereto), and foreign corporations that acquire substantially all of the properties of such domestic corporations or partnerships. This book contains: - The complete text of the Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Reasonable Compensation

Reasonable Compensation
Author: Anne E. Moran
Publisher:
Total Pages:
Release:
Genre: Corporations
ISBN: 9781558718449

" ... analyzes the issues relating to the deduction by an employer for a "reasonable allowance" under [section] 162(a) for compensation paid with regard to personal services rendered. It discusses in depth the factors applied in determining reasonableness, the necessity for the actual performance of services, situations where a deduction for reasonable compensation is not allowable, and other aspects of reasonable compensation. Various tax planning and controversy considerations also are discussed"--Portfolio description (p. iii).