The Supreme Court recently granted certiorari in the case Moore v. United States to review a Ninth Circuit Court of Appeals decision affirming application of the “transition tax” under Section 965, enacted as part of the Tax...more
Our Federal Tax Group digs into IRS Notice 2023-2 guidance on when SPAC redemptions of stock are subject to the new 1% excise tax....more
Our Federal Tax Group finds the sweet spot for corporate inversions. If a U.S. corporation’s shareholders obtain between 50% and 60% of the stock, the exchange could be taxable....more