IRS Applies Special Tax Rules to Cross-Border Corporate Acquisitions Cross-border mergers and acquisitions often involve complex U.S. tax rules that differ significantly from domestic business transactions. Even when shareholders receive mostly stock instead of cash, certain international acquisitions can trigger immediate U.S. tax consequences. The tax treatment depends largely on how the transaction is structured...

IRS Limits Advance Tax Rulings That Depend on Foreign Law Interpretation As more countries adopt new international tax rules, many businesses have asked whether foreign taxes qualify for U.S. Foreign Tax Credits. The IRS has made it clear that these questions generally cannot be answered with a blanket ruling. Instead, the tax treatment often depends...

IRS Generally Will Not Issue Advance Tax Rulings on Proposed Legislation Businesses and taxpayers often want to know how pending legislation could affect future tax planning. However, the IRS generally will not issue advance letter rulings or determination letters explaining the federal tax consequences of laws that have not yet been enacted. Instead, taxpayers must...

IRS Limits Advance Tax Rulings on Corporate Inversions Corporate inversions remain a major area of IRS scrutiny. These transactions generally involve a U.S. corporation or partnership restructuring under a foreign parent company, often with the goal of changing the group’s tax residence. Although the tax rules under Section 7874 remain in effect, the IRS generally...