On August 7, 2022, the US Senate passed the Inflation Reduction Act of 2022 (the Act), a budget reconciliation bill recently introduced by Senate Majority Leader Chuck Schumer (D-NY) and Senator Joe Manchin (D-WV). The bill...more
The purpose of section 367(b) in the context of an inbound section 332 liquidation or section 368 reorganization (inbound asset transfer) is to ensure that the domestic acquiring corporation (or domestic shareholder of the...more
Tax Reform and All Cash D Reorganizations -
With the introduction of global intangible low-taxed income (GILTI) as a new category of income of controlled foreign corporations (CFCs) currently taxable in the United States...more
In an important taxpayer victory, a Minnesota District Court ruled in favor of Wells Fargo, holding that the measurement and analysis of its uncertain tax positions was protected from disclosure by the work product privilege....more