A team of BakerHostetler lawyers, led by Partners Andrew Grossman and Jeff Paravano, represented clients Charles and Kathleen Moore at the Supreme Court, arguing that realization is required for federal taxation of income...more
The U.S. Supreme Court today upheld the constitutionality of the so-called “mandatory repatriation tax” in a narrow ruling, stating that the MRT taxes realized income — income earned by the offshore corporation — and...more
The White House and Treasury today released the Fiscal Year 2022 Federal Budget and the Treasury Green Book, which include new details regarding the Biden administration’s American Families Plan and proposed 2021 tax changes...more
With release by the White House and Treasury of initial details regarding Biden Administration proposed 2021 tax reform, a primary focus in Washington, D.C., for the next seven months or so will be expected changes to the tax...more
With the passage of the Biden Administration’s COVID-19 relief bill, the focus in Washington, D.C., has shifted to Administration plans for investment in infrastructure and related items and significant tax changes to help...more
With expected passage in the next few weeks of the Biden Administration’s first COVID-19 relief bill, the focus in Washington, D.C., will shift to a second budget reconciliation bill – Biden Administration tax changes. The...more
The Treasury Department and the IRS published proposed regulations yesterday on the Base Erosion and Anti-Abuse Tax (BEAT) that was enacted by the Tax Cuts and Jobs Act of 2017. ...more
Recently proposed IRS regulations materially change the way stock and assets of foreign corporations that are “controlled foreign corporations” (CFCs) can be used to support debt of U.S. affiliates. ...more