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
Mark your calendars to join us for our year-in-review program that will cover key tax and employee benefits issues affecting the state and local, federal and international legal landscape. We will conclude our program with...more
12/2/2022
/ Compensation & Benefits ,
Employee Benefits ,
Events ,
Federal Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Local Taxes ,
State Taxes ,
Tax Liability ,
Tax Planning
On November 2, 2022, the Supreme Court of the United States announced that the case of Whirlpool Financial Corp., et al., Petitioners v. Commissioner of Internal Revenue, No. 22-9, has been distributed for consideration at...more
On September 23, 2022, the Internal Revenue Service (IRS) released a memorandum (AM 2022-003) concluding that taxpayers cannot make advance payments of section 367(d) inclusions except in the limited situation in which the US...more
On August 10, 2022, a petition for writ of certiorari filed by Whirlpool Financial Corporation & Consolidated Subsidiaries and Whirlpool International Holdings S.a.r.l. & Consolidated Subsidiaries (collectively, Whirlpool)...more
The US Court of Appeals for the Sixth Circuit recently issued its opinion in Whirlpool Financial Corporation & Consolidated Subsidiaries v. Commissioner, affirming the decision made by the US Tax Court. The Tax Court held...more
Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape.
Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more
10/21/2021
/ Business Taxes ,
Continuing Legal Education ,
Corporate Taxes ,
Federal Taxes ,
Income Taxes ,
International Tax Issues ,
IRS ,
Local Taxes ,
Multinationals ,
Partnerships ,
Proposed Legislation ,
SALT ,
State Taxes ,
Tax Legislation ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Webinars
CFOs of recently de-SPAC’ed* and newly public companies face significant challenges. High on the list is the recently released Made in America Tax Plan, through which the Biden administration proposed significant changes to...more
5/21/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Biden Administration ,
CFOs ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Green Book ,
Made in the USA ,
Mergers ,
Proposed Regulation ,
Publicly-Traded Companies ,
Special Purpose Acquisition Companies (SPACs) ,
Tax Increases
Please join us for our inaugural Tax in the City® in San Francisco—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and confidential setting.
Our...more
5/4/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Continuing Legal Education ,
Federal Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
OECD ,
Partnerships ,
State Taxes ,
Tax Planning ,
Webinars
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
We invite you to join us for a discussion on current tax issues including:
• Judicial deference and potential impact on TCJA audits
• Developments and planning considerations for intangible assets
o US tax...more
9/25/2019
/ Asset Management ,
Continuing Legal Education ,
EU ,
Events ,
Income Taxes ,
Intangible Property ,
International Tax Issues ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
UK Brexit
A domestic corporation's royalty income derived in connection with business conducted outside the United States generally is eligible for the reduced 13.125 percent effective tax rate on foreign derived intangible income...more
Income from the sale of inventory by a domestic corporation generally is sourced based on where title and risk of loss to the property pass to the buyer. Thus, income from the sale of inventory where title passes outside the...more
Under Subpart F, certain types of income and investments of earnings of a foreign corporation controlled by US shareholders (controlled foreign corporation, or CFC) are deemed distributed to the US shareholders and subject to...more