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Five Tax Cases that May Impact Your Business 2024

The book has closed on 2023, but several recent tax-related rulings are sure to have ripple effects into 2024 and beyond—particularly with respect to transfer pricing and foreign tax credits. Here are five cases that will...more

Fenwick Writes Comment Letter on Notice 2023-63 on Amortization of Specified Research or Experimental Expenditures under Section...

Following the IRS’s issuance of guidance in Notice 2023-63 regarding R&D capitalization under Section 174, a working group of several Fenwick tax group attorneys commented to the IRS and the U.S. Treasury Department on...more

New Proposed FTC Regulations Provide Limited Relief

In the newly released Proposed Foreign Tax Credit (FTC) Regulations, Treasury provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the Final FTC Regulations that...more

The FDII Final Regulations Are Here: An Executive Summary and Observations

Treasury and the IRS released final section 250 regulations on July 9, 2020, primarily focused on the deduction for foreign-derived intangible income (FDII). The final regulations make significant revisions to the proposed...more

Treasury Finalizes Section 901(m) Foreign Credit Rules

On March 20, 2020, Treasury and the IRS released final regulations under Section 901(m). The regulations were published in the Federal Register on March 23, and generally apply to covered asset acquisitions (CAAs) occurring...more

Proposed Guidance on the Production Sourcing Rules under New Section 863(b)

The Tax Cuts and Jobs Act (TCJA) repealed the long-standing “50/50” sourcing rule for United States exporters of manufactured products. Under the new rules, which source income of a “producer” solely to the place of...more

Treasury and IRS Release Final and Proposed Foreign Tax Credit Regulations

On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more

Treasury and IRS Propose Welcome (and Some Unwelcome) Guidance on the Base Erosion and Anti-Abuse Tax

Treasury and the IRS have issued proposed regulations filling a number of gaps and providing necessary guidance on the Base Erosion and Anti-Abuse Tax (BEAT). In general, the guidance is reasonably consistent with the statute...more

Section 385 Proposed Regulations

On April 4, 2016, Treasury and the IRS proposed sweeping regulations under § 385 of the Code. Issued the same day as the anti-inversion temporary regulations, the proposed § 385 rules would go much farther than merely...more

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