Weil Tax BLOG - Feed https://tax.weil.com/contributor/stephanie-galvis/ Views and developments from the Tax Department at Weil Wed, 30 Sep 2026 21:19:42 +0000 hourly 1 Proposed Treasury Regulations Implement OBBBA Changes to CFC Pro Rata Share Rules for Subpart F Income, Tested Income, or Tested Loss https://tax.weil.com/insights/proposed-treasury-regulations-implement-obbba-changes-to-cfc-pro-rata-share-rules-for-subpart-f-income-tested-income-or-tested-loss/ Wed, 26 Aug 2026 20:30:17 +0000 Devon Bodoh Stephanie Galvis George Vallejo https://tax.weil.com/?p=2689 On August 26, 2026, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) published proposed regulations (REG-115646-25) under Sections 951 and 951A addressing the determination of a U.S. shareholder’s pro rata share of a controlled foreign corporation’s (“CFC”) subpart F income (as defined in Section 952 of the Code), tested income, or tested

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]]> On August 26, 2026, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) published proposed regulations (REG-115646-25) under Sections 951 and 951A addressing the determination of a U.S. shareholder’s pro rata share of a controlled foreign corporation’s (“CFC”) subpart F income (as defined in Section 952 of the Code), tested income, or tested

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]]> IRS Issues Important Cross Border Proposed Regulations https://tax.weil.com/insights/irs-issues-important-cross-border-proposed-regulations/ Thu, 05 Dec 2024 15:11:40 +0000 Devon Bodoh Grant Solomon Stephanie Galvis https://tax.weil.com/?p=2393 On November 29, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) announced proposed regulations (the “Proposed Regulations”) (REG-105479-18) regarding previously taxed earnings and profits (“PTEP”) of foreign corporations and related basis adjustments. The IRS requests public comments on the proposed rulemaking, which aims to clarify the tax consequences of PTEP under Sections

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