Joshua Milgrim

Joshua Milgrim

Dechert LLP

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The New Landscape for Inversions: IRS and Treasury Change the Rules

The Internal Revenue Service (“IRS”) and Treasury Department issued Notice 2014-52 (the “Notice”) targeting corporate inversions on September 22, 2014 (the “Notice Date”) in the U.S. Tax considerations are important for...more

10/1/2014 - Controlled Foreign Corporations Corporate Taxes Cross-Border Foreign Subsidiaries Inversions IRS Multinationals Notice 2014-52 U.S. Treasury

U.S. Department of Justice Awaits Swiss Banks’ Voluntary Disclosure of Banking Activities

The U.S. Department of Justice (“DOJ”) established a Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”) on August 29, 2013. The Program is intended to facilitate a resolution with the...more

10/11/2013 - Banks DOJ EU Foreign Bank Accounts Non-Prosecution Agreements Non-Target Letters Tax Evasion Voluntary Disclosure

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