Keeping it in the family just got more complicated. Our Tax Group studies a Supreme Court decision that left a family with an unexpected estate tax liability related to a share redemption agreement....more
Our Federal & International Tax Group examines a long-awaited Tax Court ruling that helps clarify when a non-U.S. company engages in a “U.S. trade or business.”...more
Our International Tax Group delves into the attribution requirement (née jurisdictional nexus requirement) of the final foreign tax credit regulations and finds that taxpayers will still face uncertainties in the application...more
With the release of its FY 2022 revenue proposals, the Biden Administration explains and refines some of the tax priorities raised on the campaign trail. Our International Tax Group reads the tea leaves to find the...more
The Tax Cuts and Jobs Act of 2017 continues to reverberate even unto the end of 2020. Our International Tax Group discusses a letter ruling that may have been a harbinger of proposed regulations to address exceptions to...more
Our International Tax Group examines the high-tax exclusion (HTE) in new final regulations under the global intangible low-taxed income (GILTI) regime and the potentially precarious side effects U.S. shareholders face in...more
The IRS’s final regulations for Section 250 deductions for FDII and GILTI are here for your light summer reading. Better yet, let our International Tax Group explain it all for you....more
Government-ordered travel restrictions have kept taxpayers far from home, but new IRS guidance provides some relief. Our International Tax Group translates the Revenue Procedures and FAQs into plain English....more
Is your inventory sales income U.S. or foreign source? Well, it depends. Our International Tax Group explores the various sourcing rules the IRS has proposed to sort out possible inconsistencies and overlaps caused by the Tax...more
Our International Tax Group parses a recent federal appellate court ruling in the ongoing battle between the IRS and taxpayers over the maximum penalty for willfully failing to file an FBAR to report offshore accounts as...more
Tucked away in the recently enacted Tax Cuts and Jobs Act is a provision dealing specifically with S corporations. It is one of these particular provisions that caused the Internal Revenue Service to recently issue a notice...more
At long last, we have the first set of final regulations for the Tax Cuts and Jobs Act. Our International Tax Group celebrates with a look at how the Treasury and IRS have clarified Section 965 and why taxpayers may need to...more
In long-awaited guidance on Section 163(j) post-tax reform, the Treasury and IRS present taxpayers with an expansive definition of “interest,” subjective anti-abuse rules, complex computational instructions, and several...more
Every U.S. person who has a financial interest in, or signature authority over, any foreign financial accounts (including bank accounts, securities, or other types of financial accounts located outside of the U.S.) must file...more
The Tax Cuts and Jobs Act replaced the earnings stripping rules with a new limitation on deductions for business interest expense. Our International Tax Group examines the new law and what it means for interest expense...more
The Tax Cuts and Jobs Act, signed into law on December 22, 2017, represents the biggest change to U.S. tax law since adoption of the 1986 Code. In addition to rate cuts and various individual and corporate reforms, the Act...more
Comprehensive tax reform is moving rapidly, and both the House and the Senate have proposed their own versions of tax reform. Our International Tax and Tax Policy & Regulation Groups investigate the differences between the...more
With tax reform on the horizon, Treasury takes aim at three sets of regulations with clear cross-border implications. Our International Tax Group explains the department’s recommendations to scrap much of Section 385 and...more
Modeled after the Foreign Account Tax Compliance Act (FATCA) – the U.S.’s information reporting regime for U.S. holders of foreign accounts – the Organisation for Economic Co-Operation and Development (OECD) approved the...more
A foreign investor, not engaged in a U.S. trade or business, can sell stock in a U.S. corporation without fear of U.S. tax liability (with the notable exception of stock in certain U.S. corporations heavily invested in U.S....more
Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all...more
Doubling down on his promise to achieve monumental tax reform, President Trump on April 26 issued a tax reform plan outlining his Administration’s broad aims. Once again, he has made it clear that large-scale tax reform is a...more
On January 18, 2017, the IRS issued temporary and proposed regulations (T.D. 9814) under Section 721(c) to address transfers of appreciated property by U.S. persons to partnerships with related foreign partners. With some...more
On December 28, 2016, the Treasury issued final regulations (T.D. 9806) that primarily address passive foreign investment company (PFIC) ownership and reporting rules and largely adopt 2013 proposed (REG-140974-11) and...more
On October 13, the Treasury released highly anticipated final and temporary regulations (T.D. 9790) under Section 385,
which authorizes the Treasury to devise regulations to determine when an interest in a corporation is...more