New Regs May Substantially Impact Multinational Financing

Law360 (November 9, 2018, 3:21 PM EST) -- On Oct. 31, 2018, the IRS released proposed regulations that, if finalized, may substantially impact the way in which multinational corporations finance their operations. The proposed regulations’ stated goals are aimed at maintaining taxpayer neutrality between repatriating cash of offshore subsidiaries through the use of distributions or investments by the subsidiary in U.S. property. However, the proposed regulations also have the effect of denying indirect foreign tax credits that may otherwise be available in respect of a Section 956 inclusion.

Historically (i.e., prior to January 2018), taxpayers could achieve some level of deferral with respect to offshore earnings through the use...

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