Cym H. Lowell

Cym H. Lowell

McDermott Will & Emery

Contact  |  View Bio  |  RSS

Latest Publications


Focus on Tax Strategies & Developments - August 2016

Brexit: The Consequences for International Tax Planning - Just over a month has now passed since the referendum in which the United Kingdom voted narrowly to leave the European Union: an event which some have...more

8/16/2016 - Derivatives Derivatives Tax Act EU International Tax Issues Member State Referendums Tax Planning Transfer Taxes UK UK Brexit Value-Added Tax

Focus on Tax Strategies & Developments - January 2016

Protecting Americans from Tax Hikes Act of 2015—the Year-End Legislation f/k/a Extenders - Just in time for Christmas, Congress passed, with bipartisan support, and the President signed, the “Protecting Americans from...more

2/1/2016 - Audits Bipartisan Budget FIRPTA Holding Companies International Tax Issues Italy LLC Multinationals OECD Partnership Agreements Protecting Americans from Tax Hikes (PATH) Act REIT Tax Extenders Tax Extensions The Patent Box UK

International News: Focus on Tax - Issue 3, 2015

The breadth of the articles contained in our Focus on Tax this issue demonstrates the perennial importance of this topic to global businesses and international high net worth individuals. We examine topics ranging from...more

12/14/2015 - Anti-Bribery China Competition Appeal Tribunal Double Taxation EU EU Data Protection Laws Foreign Investment General Data Protection Regulation (GDPR) Holding Companies Hospitals Institutional Investors Italy OECD Patents Trusts UK UK Consumer Rights Act

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

11/12/2014 - Corporate Taxes FATCA Income Taxes Inversion Mortgages Real Estate Market REIT Spinoffs Subpart F Tax Structuring

Focus on Tax Controversy - Spring 2014

Company Jet Audit Issues: A Word to the Wise - Once a business attains a certain level of success, an aircraft often becomes a valued asset. Public and closely held private companies alike find that the use of a...more

3/18/2014 - Aircraft Audits Corporate Taxes IRS

Russian Transfer Pricing Law

Recently enacted Russian transfer pricing rules now require companies operating in Russia to file annual documentation in compliance with new regulatory guidance regarding related foreign party and certain domestic party...more

2/26/2013 - Advance Pricing Arrangement Program Annual Filings Audits International Tax Issues OECD Penalties Required Documentation Transfer Pricing

Multilateral Advance Pricing Agreements

As transfer pricing examination and controversy continue to grow, it’s becoming increasingly common for a multinational enterprise group to have advance pricing agreements (APA) with more than two countries (typically...more

1/16/2013 - Advance Pricing Arrangement Program Transfer Pricing

Worthless Stock Deductions: Valuation, Transfer Pricing and Technical Considerations

When a multinational enterprise (MNE) has affiliates that have become insolvent, the overall tax planning objective frequently is to secure a U.S. tax deduction (often ordinary) for worthless stock or debt. The essential...more

12/7/2012 - Multinationals Transfer Pricing Valuation

Effective Resolution of BRICS Country Transfer Pricing Disputes

In the evolving world of international transfer pricing, it can be risky to assume that planning strategies to achieve the lowest possible effective tax rates, as encouraged by the operative provisions of the Organisation for...more


9 Results
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.