Mark your calendars to join us for our year-in-review program that will cover key tax and employee benefits issues affecting the state and local, federal and international legal landscape. We will conclude our program with...more
12/2/2022
/ Compensation & Benefits ,
Employee Benefits ,
Events ,
Federal Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Local Taxes ,
State Taxes ,
Tax Liability ,
Tax Planning
The potential impact of global mobility issues and recent tax developments may require reassessing your planning strategies.
Join us for our first Tax in the City® program of 2022, which will cover federal and...more
2/7/2022
/ Captive Insurance Company ,
Federal Taxes ,
Foreign Tax Credits ,
International Tax Issues ,
Multinationals ,
New Regulations ,
OECD ,
Passive Foreign Investment Company ,
Remote Working ,
Risk Mitigation ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Webinars ,
Women in the Law
Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape.
Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more
10/21/2021
/ Business Taxes ,
Continuing Legal Education ,
Corporate Taxes ,
Federal Taxes ,
Income Taxes ,
International Tax Issues ,
IRS ,
Local Taxes ,
Multinationals ,
Partnerships ,
Proposed Legislation ,
SALT ,
State Taxes ,
Tax Legislation ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Webinars
Please join us for our inaugural Tax in the City® in San Francisco—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and confidential setting.
Our...more
5/4/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Continuing Legal Education ,
Federal Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
OECD ,
Partnerships ,
State Taxes ,
Tax Planning ,
Webinars
What should in-house lawyers spend time discussing with their chief financial officers (CFOs)? What are the most important tax developments affecting businesses today? In this program, we’ll review the key tax issues that...more
4/29/2021
/ Business Taxes ,
Captive Insurance Company ,
CFOs ,
COBRA ,
Continuing Legal Education ,
Contract Renewal ,
Corporate Counsel ,
Insurance Contracts ,
Remote Working ,
Risk Management ,
Risk Mitigation ,
Tax Liability ,
Tax Planning ,
Webinars
The final debt-equity regulations issued on May 13, 2020, finalize proposed section 385 regulations issued in 2016 without any substantive changes to the existing debt-equity regulations, and withdraw the temporary section...more
We invite you to join us for our Tax in the City®: A Women’s Tax Roundtable in Seattle.
We plan to discuss, among other topics, post-TCJA tax treatment of foreign branches (and disregarded entities), new BEAT guidance, an...more
5/4/2020
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Business Taxes ,
Continuing Legal Education ,
Digital Taxes ,
Economic Presence Nexus ,
Events ,
Foreign Corporations ,
Income Taxes ,
International Tax Issues ,
OECD ,
Out-of-State Companies ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning
Mark your calendars for our spring 2020 Tax in the City®: A Women’s Tax Roundtable in Seattle—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and...more
2/19/2020
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Business Taxes ,
Continuing Legal Education ,
Digital Taxes ,
Economic Presence Nexus ,
Events ,
Foreign Corporations ,
Income Taxes ,
International Tax Issues ,
OECD ,
Out-of-State Companies ,
State Taxes ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning
We invite you to join us for our annual “Year in Review” Tax in the City® Chicago. We will discuss current tax issues including:
• Judicial deference and potential impact on TCJA audits
• Taxation of the digitalized...more
11/27/2019
/ Continuing Legal Education ,
Digital Assets ,
Events ,
Income Taxes ,
International Tax Issues ,
Judicial Deference ,
New Guidance ,
State Taxes ,
Tax Audits ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Litigation ,
Tax Planning
We invite you to join us for a discussion on current tax issues including:
• Judicial deference and potential impact on TCJA audits
• Developments and planning considerations for intangible assets
o US tax...more
9/25/2019
/ Asset Management ,
Continuing Legal Education ,
EU ,
Events ,
Income Taxes ,
Intangible Property ,
International Tax Issues ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
UK Brexit
Section 163(j), as recently amended, may limit a taxpayer’s interest expense deduction. Notice 2018-28, in very general terms, provides interim guidance on the application of Section 163(j).
Importantly, the Notice...more
On December 22, 2017, President Trump signed broad tax reform legislation into law that, among other things, reduced the corporate income tax rate to 21 percent and reformed the US international tax system. This article...more
The final US tax legislation includes a number of provisions that will impact the property & casualty (P&C) insurance sector, including captive insurance companies. Specific to the insurance sector are new rules for computing...more
A number of provisions included in the Senate’s tax reform bill, H.R. 1 (the Senate Bill) would impact the insurance sector. Many of the provisions would affect only the life insurance industry. Others affect property &...more
In a long-awaited decision, the Tax Court recently held that gain realized by a foreign taxpayer on the sale of a partnership engaged in a US trade or business was a sale of a capital asset not subject to US tax, declining to...more
IRS Updates Administrative Appeals Process for Cases Docketed in Tax Court -
In Notice 2015-72, the Internal Revenue Service (IRS) provided a proposed revenue procedure to update Rev. Proc. 87-24, 1987-1 C.B. 720, which...more
12/16/2015
/ Administrative Appeals ,
Attorney-Client Privilege ,
Estate Tax ,
Good Faith ,
Income Taxes ,
Insurance Contracts ,
IRS ,
Multistate Tax Compact ,
Retroactivity ,
Tax Court ,
Tax Litigation ,
Tax Shelters ,
WA Supreme Court
Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations -
Introduction:
On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more
10/5/2015
/ Administrative Procedure Act ,
Amended Regulation ,
BEPS ,
Clawbacks ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Cost-Sharing ,
Foreign Corporations ,
Goodwill ,
Intangible Property ,
IRC Section 367 ,
IRS ,
Partnerships ,
Proposed Regulation ,
Section 482 ,
Stock-Based Compensation ,
Tax Court ,
Tax Reform ,
Transfer Pricing ,
Transfers ,
U.S. Treasury
On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Temporary Regulation § 1.954-2T concluding that third party arrangements cannot be taken into account for...more
9/25/2015
/ Controlled Foreign Corporations ,
Corporate Officers ,
Cost-Sharing ,
Employees ,
IRS ,
New Regulations ,
Ordinary Business Exception ,
Rent ,
Royalties ,
Safe Harbors ,
Subpart F ,
Third-Party ,
U.S. Treasury
On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued new temporary Treasury regulations addressing the application of Internal Revenue Code Section 956 to certain...more
9/22/2015
/ Anti-Abuse Rule ,
Anti-Avoidance ,
Controlled Foreign Corporations ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Partnerships ,
Section 956 ,
Shareholders ,
Tax Avoidance ,
U.S. Treasury
On August 6, 2015, 18 years after U.S. Congress authorized regulations under Internal Revenue Code Section 721(c), the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released Notice 2015-54 announcing...more
8/25/2015
/ Capital Gains ,
Cost-Sharing ,
Foreign Corporations ,
Intangible Property ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
New Regulations ,
Partnerships ,
Property Transaction Taxes ,
U.S. Treasury
In This Issue:
- Distinguishing Between Captive Insurance and Related Party Derivatives: Chief Counsel Advice Memorandum 201511021
- Achieving Tax-Free ‘Rollover’ Treatment for Certain Shareholders in Acquisition of...more
In This Issue:
Features -
..The UK Response to BEPS and Hybrid Mismatches
..Parental Liability for French Subsidiaries
..The Evolving US-Cuba Trade Landscape
..Amendments to Taiwan Fair...more
On May 18, 2014, the Internal Revenue Service (IRS) ruled that an employer’s wholly owned captive insurance subsidiary could reinsure the employer’s retiree medical benefit risks and still qualify as insurance for federal tax...more
Delaware Court of Chancery Upholds Forum Selection Bylaws -
In recent years, virtually every merger and acquisition (M&A) transaction of significant size involving a U.S. public company has been challenged in court. ...more
In a newly released Chief Counsel Advice, the Internal Revenue Service (IRS) Office of Chief Counsel treated a collaboration arrangement relating to the development and commercialization of a drug as a deemed partnership for...more