As the Tax Section celebrates its 75th anniversary, I was asked to reflect on the Section’s contribution in the international tax arena and on how the Section’s international community has grown. I started by recognizing the...more
CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes.
Do you have responsibility, whether direct or dotted line, for the tax function in your...more
In this interview with The Deal’s Jon Marino, Pepper Hamilton LLP's Joan Arnold, a partner who heads the firm's tax group, says Pfizer’s play for AstraZeneca isn’t the only inversion deal being sought. There are no shortages...more
In this Presentation:
- Inversions – How Did We Get Here?
- Impact Of The §367 Regulations
- 2003 – Enactment of §7874
- Determining “Ownership”
- Treasury Regulation...more
FATCA is the new form of 30% U.S. withholding tax that is applied to U.S. source income, such as interest and dividends paid by U.S. companies, starting as early as July 1, 2014 for payments made to non-U.S. entities that are...more
In response to taxpayer concerns about the practicality of meeting certain FATCA compliance timeline dates, the IRS, in Notice 2013-43 issued today, has extended some of those dates and made certain conforming changes. ...more
In December, Bank Leumi le-Israel BM issued a letter notifying its U.S. account holders about the IRS Offshore Voluntary Disclosure Initiative (the OVDI). The IRS OVDI is a type of amnesty program under which U.S. citizens...more
In late October PE Manager brought together four industry professionals (Joan Arnold, Pepper Hamilton; Kristy Trieste, Corsair Capital; Lori Evans, Birch Hill Equity Partners; and Jay Bakst, EisnerAmper) who must all in their...more