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Moore questions: Impressions from oral argument

On December 5, 2023, the US Supreme Court heard oral arguments in Moore v. United States, addressing the constitutionality of the section 965 transition tax, which was enacted in the Tax Cuts and Jobs Act of 2017. Section 965...more

Five things to know about the Supreme Court’s grant of certiorari in Moore v. United States

The Supreme Court granted certiorari on June 26 with respect to the Ninth Circuit’s decision in Moore v. United States. The question presented is whether the section 965 transition tax is a “direct tax” that violates the...more

Second time’s the charm? New proposed section 163(j) regulations treat electing CFC groups as a single corporation and eliminate...

Significant provisions of the 2020 Proposed Regulations addressing the application of section 163(j) to foreign corporations and their shareholders include: ..An election under which a controlled foreign corporation (CFC)...more

LB&I announces new campaigns – Related-party service companies, offshore private banking and loose-filed Forms 5471

On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on: ..Transfer pricing for “captive” services...more

Deemed participation better than no participation? Proposed regulations expand tax-free treatment to section 956 inclusions of...

On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of the Internal Revenue Code of...more

FY 2016 Budget Tax Proposals Target Insurance Companies

On February 2, the Obama Administration released its fiscal year 2016 budget (FY 2016 Budget). The hallmarks of the FY 2016 Budget are proposals that would impose (i) a minimum tax on the current foreign earnings of U.S....more

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