The U.S. Supreme Court has affirmed the Ninth Circuit's decision in Moore v. United States, upholding the constitutionality of the mandatory repatriation tax enacted in 2017....more
The Internal Revenue Service ("IRS") recently issued important guidance identifying new positions the IRS is considering on critical aspects of tax-free spin-offs, and significantly expanding the information that taxpayers...more
On April 9, 2024, the U.S. Treasury Department ("Treasury") issued proposed regulations and reporting requirements providing further guidance on the non-deductible 1% excise tax that was enacted on August 16, 2022 (as Section...more
5/6/2024
/ Cross-Border ,
Cross-Border Transactions ,
Excise Tax ,
Internal Revenue Code (IRC) ,
IRS ,
Merger Agreements ,
New Guidance ,
Proposed Regulation ,
Reporting Requirements ,
Share Buybacks ,
U.S. Treasury
Proposed regulations addressing new tax reporting requirements for cryptocurrencies and other digital assets have been issued by the IRS and Treasury....more
In Short -
The Situation: A new nondeductible 1% excise tax imposed on certain stock repurchases (enacted as new section 4501 as part of the Inflation Reduction Act on August 12, 2022) (the "Stock Buy-back Excise Tax")...more
The enforcement of the District's tax laws had previously been left exclusively to government agencies; a newly enacted bill will make the District one of a few jurisdictions to allow relators to bring qui tam suits alleging...more
Proposed IRS regulations clarify when fines and penalties are deductible but leave important issues unresolved.
The U.S. Internal Revenue Service has released proposed regulations clarifying when fines, penalties, and...more
The Situation: On June 14, 2019, the IRS and U.S. Treasury released more than 500 pages of proposed, temporary, and final regulations addressing the taxation of U.S.-controlled foreign corporations.
The Development:...more
6/25/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Tax ,
GILTI tax ,
IRS ,
Multinationals ,
New Rules ,
Partnerships ,
Proposed Regulation ,
Retroactive Taxes ,
Stocks ,
U.S. Treasury
Virtual currencies (often called cryptocurrencies) such as bitcoin are perhaps blockchain's best-known application. As these and other blockchain-based digital assets become more common, and attract more regulatory and...more
5/2/2019
/ Blockchain ,
Cryptocurrency ,
Distributed Ledger Technology (DLT) ,
Financial Transactions ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Internal Revenue Code (IRC) ,
IRS ,
Popular ,
Reporting Requirements ,
Tax Planning ,
Token Sales ,
Virtual Currency
Just in time for tax return filing, much-needed guidance has been issued on the application of the transition tax on foreign subsidiaries' earnings imposed under last year's tax reform.
On August 1, 2018, proposed...more
On March 23, 2017, the U.S. Tax Court issued its long-awaited opinion in a transfer pricing dispute involving Amazon's cost sharing arrangement ("CSA") with its Luxembourg subsidiary...
...more