Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape.
Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more
10/21/2021
/ Business Taxes ,
Continuing Legal Education ,
Corporate Taxes ,
Federal Taxes ,
Income Taxes ,
International Tax Issues ,
IRS ,
Local Taxes ,
Multinationals ,
Partnerships ,
Proposed Legislation ,
SALT ,
State Taxes ,
Tax Legislation ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Webinars
Please join us for our inaugural Tax in the City® in San Francisco—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and confidential setting.
Our...more
5/4/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Continuing Legal Education ,
Federal Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
OECD ,
Partnerships ,
State Taxes ,
Tax Planning ,
Webinars
In a long-awaited decision, the Tax Court recently held that gain realized by a foreign taxpayer on the sale of a partnership engaged in a US trade or business was a sale of a capital asset not subject to US tax, declining to...more
Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations -
Introduction:
On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more
10/5/2015
/ Administrative Procedure Act ,
Amended Regulation ,
BEPS ,
Clawbacks ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Cost-Sharing ,
Foreign Corporations ,
Goodwill ,
Intangible Property ,
IRC Section 367 ,
IRS ,
Partnerships ,
Proposed Regulation ,
Section 482 ,
Stock-Based Compensation ,
Tax Court ,
Tax Reform ,
Transfer Pricing ,
Transfers ,
U.S. Treasury
On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued new temporary Treasury regulations addressing the application of Internal Revenue Code Section 956 to certain...more
9/22/2015
/ Anti-Abuse Rule ,
Anti-Avoidance ,
Controlled Foreign Corporations ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Partnerships ,
Section 956 ,
Shareholders ,
Tax Avoidance ,
U.S. Treasury
On August 6, 2015, 18 years after U.S. Congress authorized regulations under Internal Revenue Code Section 721(c), the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released Notice 2015-54 announcing...more
8/25/2015
/ Capital Gains ,
Cost-Sharing ,
Foreign Corporations ,
Intangible Property ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
New Regulations ,
Partnerships ,
Property Transaction Taxes ,
U.S. Treasury
In a newly released Chief Counsel Advice, the Internal Revenue Service (IRS) Office of Chief Counsel treated a collaboration arrangement relating to the development and commercialization of a drug as a deemed partnership for...more