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
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
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