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Curve-Flattening Travel Immobility Leads to Cross-Border Tax Challenges for Companies and Employees

Covid-19 is creating unexpected tax exposure for foreign-based businesses with employees detained in the US and vice versa as companies may now find themselves with more sourced income than expected causing unforeseen tax...more

Proposed Regulations under Sections 863(b) and 865(e)(2) Revise the Rules for Sourcing Income

Proposed regulations under Sections 863(b) and 865(e)(2) implement changes by TCJA to section 863(b), the primary sourcing provision for income from the sale of inventory produced by a taxpayer without and sold within the...more

Expansion of Subpart F under the Tax Reform Act

Under Subpart F, certain types of income and investments of earnings of a foreign corporation controlled by US shareholders (controlled foreign corporation, or CFC) are deemed distributed to the US shareholders and subject to...more

Tax Reform Conference Committee Reaches Agreement

A House-Senate conference committee has reached agreement on a compromise version of the Tax Cuts and Jobs Act, which includes substantial changes to the corporate and international business taxation rules. The stage now...more

Senate Tax Proposal Includes Comprehensive Business Tax Reform Measures

The Senate Finance Committee Chairman’s Mark of the Tax Cuts and Jobs Act includes substantial proposed changes to the corporate and international business taxation rules. While this proposal will evolve further in committee...more

Chairman Brady Introduces Long-Awaited Bill Including Comprehensive Business Tax Reform Provisions

The newly introduced Tax Cuts and Jobs Act is a comprehensive tax reform package that touches virtually every area of the tax law. Though largely consistent with September’s tax reform Framework, new details reveal the...more

Republican Leaders Release Tax Reform Framework

The White House and Republican congressional leadership released an outline this week to guide forthcoming legislation on tax reform. This outline will serve as a useful framework in structuring what will be an active, and...more

Is a Business Tax Reform Game Plan Beginning to Take Shape?

Substantial tax reform is underway and the business community is intently awaiting details of this activity with the aim of positioning themselves to maximize opportunities and minimize any costs or risks that reform may...more

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