Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
5/2/2024
/ Acquisitions ,
Best Practices ,
Continuing Legal Education ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Corporate Transparency Act ,
Cross-Border ,
Digital Advertising Tax ,
Digital Goods ,
Energy Tax Incentives ,
Events ,
Family Offices ,
Federal Taxes ,
Foreign Assets ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
Income Taxes ,
Internet Tax Freedom Act ,
IRS ,
Mergers ,
Multinationals ,
OECD ,
Passive Foreign Investment Company ,
Pillar 2 ,
Reorganizations ,
Research and Development ,
Tax Credits ,
Tax Legislation ,
Tax Liability ,
Tax Litigation ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Virtual Currency
BACKGROUND: SECTION 367(D) Section 367(d) generally addresses outbound transfers of intangible property to a foreign corporation. It treats a US transferor that transfers intangible property subject to Section 367(d) as...more
INTRODUCTION TO US TAXATION OF NFTS -
Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more
5/5/2022
/ Asset Management ,
Buyers ,
Charitable Donations ,
Corporate Taxes ,
Cross-Border ,
Donations ,
EU ,
Foreign Tax Credits ,
Germany ,
GILTI tax ,
Global Market ,
Income Taxes ,
International Tax Issues ,
Investment ,
IRS ,
Non-Fungible Tokens (NFTs) ,
Pay-for-Performance ,
Remote Working ,
Sellers ,
Trustees ,
U.S. Treasury ,
UK ,
Withholding Tax
On January 4, 2022, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) that deny a foreign tax credit (FTC) for certain foreign withholding taxes...more
On November 12, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published proposed regulations (REG-101657-20) (the “2020 Proposed Regulations”) in the Federal Register that contain a...more
On July 9, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released Final Regulations (Final Regulations) that provide guidance on the section 250 deduction for foreign-derived intangible...more
The Treasury Department and the IRS have issued highly anticipated guidance in the area of stewardship expenses and R&D expenses. The 2019 Proposed Regulations also provide extensive guidance on allocating and apportioning...more
12/20/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Tax Credits ,
IRS ,
New Rules ,
Proposed Regulation ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
U.S. Treasury
Tax professionals are on the frontlines, responding to state, federal and international tax developments that significantly impact business objectives. California taxpayers face particularly unique challenges.
Join members...more
11/19/2019
/ Business Taxes ,
Continuing Legal Education ,
Events ,
False Claims Act (FCA) ,
Federal Taxes ,
Foreign Entities ,
Income Taxes ,
International Tax Issues ,
IRS ,
Local Taxes ,
Proposition 13 ,
Rebates ,
Sales Tax ,
State and Local Government ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Planning