Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
5/2/2024
/ Acquisitions ,
Best Practices ,
Continuing Legal Education ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Corporate Transparency Act ,
Cross-Border ,
Digital Advertising Tax ,
Digital Goods ,
Energy Tax Incentives ,
Events ,
Family Offices ,
Federal Taxes ,
Foreign Assets ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
Income Taxes ,
Internet Tax Freedom Act ,
IRS ,
Mergers ,
Multinationals ,
OECD ,
Passive Foreign Investment Company ,
Pillar 2 ,
Reorganizations ,
Research and Development ,
Tax Credits ,
Tax Legislation ,
Tax Liability ,
Tax Litigation ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Virtual Currency
Final regulations relating to the determination of the foreign tax credit following the Tax Cuts and Jobs Act were released earlier this month. Though largely similar to the proposed regulations, taxpayers may be interested...more
12/20/2019
/ Controlled Foreign Corporations ,
Corporate Counsel ,
Corporate Taxes ,
Final Rules ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Subpart F ,
Tax Cuts and Jobs Act ,
Treasury Regulations ,
U.S. Treasury
The Treasury Department and the IRS have issued highly anticipated guidance in the area of stewardship expenses and R&D expenses. The 2019 Proposed Regulations also provide extensive guidance on allocating and apportioning...more
12/20/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Tax Credits ,
IRS ,
New Rules ,
Proposed Regulation ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
U.S. Treasury
Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more
12/18/2019
/ Anti-Abuse Rule ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Business Judgment Rule ,
Corporate Taxes ,
Final Rules ,
GILTI tax ,
Income Taxes ,
IRS ,
New Regulations ,
Popular ,
Proposed Regulation ,
Revenue Procedures ,
Subpart F ,
Treasury Regulations
Until recently, the high US corporate tax rate and regime governing interest deductibility had provided a clear incentive for multinationals (particularly, non-US multinationals) to push interest expense into the United...more
REIT Spin-Offs: Recent Transactions and IRS Rulings -
Several recent corporate spin-offs in the United States have involved real estate investment trusts (REITs). Provided several requirements are satisfied, including...more