In Notice 2020-23, released on April 9, the Department of the Treasury expanded the relief offered in earlier notices to apply to a broader set of taxpayers, additional tax returns and tax payments required to be filed or...more
Until recently, the structuring of debt facilities for U.S. borrowers with foreign subsidiaries has been largely driven by IRS interpretations of section 956 of the Internal Revenue Code, which gave rise to significant tax...more
5/8/2019
/ C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Credit Facilities ,
Creditors ,
Dividends ,
IRS ,
New Rules ,
Proposed Regulation ,
Section 956 ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning
Last week, President Trump signed H.R. 1 (New Act), the new tax bill amending the Internal Revenue Code to reduce tax rates, modify policies, credits, and deductions for individuals and businesses “to provide for...more
CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes.
Do you have responsibility, whether direct or dotted line, for the tax function in your...more
In this interview with The Deal’s Jon Marino, Pepper Hamilton LLP's Joan Arnold, a partner who heads the firm's tax group, says Pfizer’s play for AstraZeneca isn’t the only inversion deal being sought. There are no shortages...more