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IRS Issues Proposed Regulations Reducing Income Inclusions under Section 956 for Certain U.S. Corporations

On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service issued proposed regulations (the "Proposed Regulations") that would generally reduce the amount that a corporate U.S. shareholder is required...more

IRS May Relax Collection of Income Prong of Section 355 Active Trade or Business Test for R&D Companies

On September 25, 2018, the Internal Revenue Service (the IRS) released a statement announcing a study of the "active trade or business" test for tax-free spin-offs under Section 355 (the ATB Test), as applied to...more

Ninth Circuit Overturns Altera and Revives Regulations on Cost Sharing of Stock-Based Compensation

On July 24, 2018, the U.S. Court of Appeals for the Ninth Circuit, in a 2-to-1 opinion, ruled in Altera Corp. v. Commissioner that Treasury Regulations involving transfer pricing promulgated in 2003 (the Regulations) complied...more

IRS Releases Final Regulations Addressing Corporate Inversions and Related Transactions

On July 11, 2018, the U.S. Treasury Department and the Internal Revenue Service (the IRS) issued final regulations under Section 7874 and related sections of the Internal Revenue Code of 1986, as amended, (the Code)...more

U.S. Supreme Court Rules That States May Impose Sales Tax Collection Obligations on Sellers Who Lack an In-State Physical Presence

On June 21, 2018, the U.S. Supreme Court ruled in South Dakota v. Wayfair, Inc. that a state can impose sales tax collection obligations on a seller without any physical presence in the taxing state, so long as the seller has...more

Recent Guidance Regarding Withholding on Certain Transfers of Partnership Interests by Non-U.S. Persons

On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-29, "Guidance Regarding the Implementation of New Section 1446(f) for Partnership Interests That Are Not Publicly...more

IRS Releases Notice Addressing the "Transition Tax" Under Section 965 of the Code

On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) released Notice 2018-26 (the Notice), which provides guidance addressing the so-called "transition tax" or "toll charge" described in...more

Senate Finance Committee Releases Its Version of the Tax Cuts and Jobs Act

After releasing summaries and various Chairman's marks, the Senate Finance Committee ("SFC") approved its tax reform bill, the "Tax Cuts and Jobs Act," on November 16, 2017 and released the legislative text of the bill to the...more

House Committee on Ways and Means Releases Tax Cuts and Jobs Act

On November 2, 2017, the House Committee on Ways and Means, led by Republican Chairman Kevin Brady, released H.R. 1, the "Tax Cuts and Jobs Act." The House Committee is expected to mark up the bill beginning on November 6,...more

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