Miles R. Chatain

Recently Issued Proposed Regulations Regarding the Taxation of Foreign Governments and Sovereign Wealth Funds
Miles R. Chatain,Victor Hollender,Michael Prehogan, November 14, 2011
On November 2, 2011, the IRS issued new proposed regulations under section 892 (the “Proposed Regulations”). The Proposed Regulations make significant changes and provide important guidance relating to the U.S. taxation of sovereign wealth funds and other foreign government investors...