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Filing a Protective Refund Claim (With a Moore Angle)

In this article, we discuss some basic considerations for preparing a protective refund claim. These considerations are particularly relevant for taxpayers whose statutes of limitations for refund claims are expiring soon and...more

Supreme Court Takes Up Constitutional Challenge to Section 965 Transition Tax

On June 26, 2023, the Supreme Court of the United States agreed to hear a rare challenge under the Sixteenth Amendment and Tax Clauses to Section 965 of the tax code. In Moore v. United States, the justices will consider...more

IRS Releases Memorandum Regarding Advance Payments of Section 367(d) Inclusions

On September 23, 2022, the Internal Revenue Service (IRS) released a memorandum (AM 2022-003) concluding that taxpayers cannot make advance payments of section 367(d) inclusions except in the limited situation in which the US...more

Finalization of Foreign Tax Credit Rules on Disregarded Payments (Effective Retroactively)

On January 4, 2022, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) published its third set of final regulations on foreign tax credits (the “Final Regulations”) since the enactment of the Tax Cuts...more

Proposed New Code Sec. 163(n) and Removal of Expense Allocation to GILTI

This column describes new proposed Code Sec. 163(n) and the proposed general removal of expense allocation to GILTI in the Build Back Better Act (the “BBBA”). This column focuses on the version of the BBBA proposed on...more

Government Releases Final Foreign Tax Credit Regulations on Stewardship and R&E Expenses

On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit regulations (the “2020 Final Regulations”) that include the allocation and...more

Elective GILTI Exclusion for High-Taxed GILTI

On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final section 951A regulations (“Final Regulations”) on an election to exclude high-tax global intangible low-taxed...more

[Webinar] Virtual Tax Forum | Tax Strategies in the COVID-19 Economic Downturn: Loss Planning and Transfer Pricing - May 1st, 1:00...

As you assess the operational impact of COVID-19 on your business, you may need to reconsider your tax planning strategies. Join us for a discussion on tax planning opportunities and pitfalls in light of market valuation...more

The CARES Act's Changes to Section 163(j): Partnership, International, and US State Tax Implications

The Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) relaxes the section 163(j) business interest expense limitation for tax years beginning in both 2019 and 2020. Intended to help taxpayers incurring...more

Treasury and the IRS Release Final Foreign Tax Credit Regulations

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

Proposed Foreign Tax Credit Regulations Provide New Rules for Allocation and Apportionment of Deductions and Creditable Foreign...

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

Final and Proposed BEAT Regulations Provide Some Relief

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

Interaction of Interest Limitation Rules in the United States and Elsewhere

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

The Revival of Section 1059 after Tax Reform

While much of the focus on tax reform has been the interpretation and implementation of the newly adopted rules, it is also worth considering how the changes adopted in tax reform have given new life to some preexisting...more

5/31/2018  /  Dividends , Federal Taxes , Tax Reform

Expense Apportionment to GILTI

Following tax reform, domestic corporate taxpayers are required to include in gross income the amount of a CFC’s income in excess of its Subpart F income and 10 percent of depreciable tangible property (referred to as GILTI)....more

Focus on Tax Strategies & Developments - November 2014

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

IRS Issues Another Significant Ruling on Spin-off of Real Estate

In certain recent transactions, a corporation distributes a subsidiary corporation holding the distributing corporation’s real estate assets to the distributing corporation’s shareholders in a tax-free “spin-off.” Not only...more

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