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
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
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
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
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
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
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
10/21/2020
/ Allocation of Funds ,
Apportionment ,
CFC ,
Foreign Tax Credits ,
GILTI tax ,
IRS ,
New Regulations ,
Popular ,
Proposed Regulation ,
Research and Development ,
Tax Cuts and Jobs Act ,
U.S. Treasury
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
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
4/29/2020
/ Business Losses ,
Business Strategies ,
Collateral ,
Continuing Legal Education ,
Coronavirus/COVID-19 ,
Economic Downturn ,
Intellectual Property Protection ,
IP License ,
OECD ,
Tax Liability ,
Tax Planning ,
Transfer Pricing ,
Webinars
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
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
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
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
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
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