Moshe Spinowitz

Moshe Spinowitz

Skadden, Arps, Slate, Meagher & Flom LLP

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Latest Publications


"New Regulations Address Outbound Transfers and Transfer Pricing"

On September 14, 2015, the Internal Revenue Service (the IRS) and Treasury Department proposed new regulations addressing the tax treatment under Section 367 of the Internal Revenue Code (the Code) of certain transfers by...more

9/21/2015 - Aggregation Rules Arms Length Transactions Controlled Transactions Covenant of Good Faith and Fair Dealing Foreign Corporations Internal Revenue Code (IRC) IRC Section 367 IRS Ordinary Business Exception Outbound Transactions Section 482 Transfer Pricing U.S. Treasury Valuation

"Challenging the IRS Anti-Inversion Notice: A Hollow Threat"

On September 22, 2014, Treasury and the IRS issued Notice 2014-52, 2014-42 I.R.B. 712 (the Notice), announcing their intention to issue regulations aimed at blunting certain of the benefits from so-called inversion...more

1/29/2015 - Administrative Procedure Act Anti-Injunction Act Declaratory Judgment Act Internal Revenue Code (IRC) Inversion IRS New Regulations U.S. Treasury

"UK Government Announces New 25 Percent Diverted Profits Tax"

On Wednesday, the U.K. Government released draft legislation to be effective on 1 April 2015, which will impose a “diverted profits tax” (DPT) at 25 percent of the amount of profits deemed to have been diverted from the U.K....more

12/12/2014 - Corporate Taxes Multinationals UK

Proposals May Signal Direction of Future Tax Reform

After several years of hearings and forums intended to develop broad-based support for comprehensive tax reform, on February 26, 2014, House Ways and Means Committee Chairman David Camp (R-Mich.) released a draft tax reform...more

4/22/2014 - Accounting Alternative Minimum Tax Corporate Taxes Debt Restructuring Derivatives Financial Products Foreign Tax Internal Revenue Code (IRC) Partnerships Subpart F Tax Credits Tax Reform Ways and Means Committee

"US Corporate Tax Reform: Stuck in Neutral"

Three significant international tax reform proposals in the United States have been released in the past three years: the International Tax Reform Discussion Draft released by House Ways & Means Committee Chairman Dave Camp...more

1/24/2014 - Corporate Taxes Tax Rates Tax Reform

"Senate Finance Chair Proposes International Business Tax Reform"

On November 19, 2013, Sen. Max Baucus (D-Mont.), Chairman of the Senate Finance Committee, released a Staff Discussion Draft on International Business Tax Reform. The changes proposed in the discussion draft are far-reaching...more

11/22/2013 - Business Taxes International Tax Issues Tax Reform

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