The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more
8/30/2024
/ Chevron Deference ,
Corporate Counsel ,
Foreign Subsidiaries ,
Foreign Tax Credits ,
Internal Revenue Code (IRC) ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Regulatory Authority ,
SCOTUS ,
Tax Court ,
Tax Liability ,
U.S. Treasury
Just in time for tax return filing, much-needed guidance has been issued on the application of the transition tax on foreign subsidiaries' earnings imposed under last year's tax reform.
On August 1, 2018, proposed...more
The Situation: The Trump Administration, in collaboration with the House and Senate, has introduced a Framework for tax reform legislation that could bring sweeping changes to U.S. tax laws....more
10/11/2017
/ Alternative Minimum Tax ,
Budget Reconciliation ,
Business Taxes ,
Corporate Taxes ,
Family Businesses ,
Foreign Subsidiaries ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
Multinationals ,
Pass-Through Entities ,
Proposed Legislation ,
Repatriation ,
S-Corporation ,
Tax Rates ,
Tax Reform ,
Trump Administration
On March 23, 2017, the U.S. Tax Court issued its long-awaited opinion in a transfer pricing dispute involving Amazon's cost sharing arrangement ("CSA") with its Luxembourg subsidiary...
...more