President-elect Donald Trump is set to return to the White House with Republicans narrowly securing both the US Senate and the US House of Representatives. Having control of both chambers positions the party well to pursue...more
12/30/2024
/ Acquisitions ,
Corporate Taxes ,
Cross-Border ,
Mergers ,
Pillar 2 ,
Political Campaigns ,
Tariffs ,
Tax Cuts ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Trump Administration
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
5/2/2024
/ Acquisitions ,
Best Practices ,
Continuing Legal Education ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Corporate Transparency Act ,
Cross-Border ,
Digital Advertising Tax ,
Digital Goods ,
Energy Tax Incentives ,
Events ,
Family Offices ,
Federal Taxes ,
Foreign Assets ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
Income Taxes ,
Internet Tax Freedom Act ,
IRS ,
Mergers ,
Multinationals ,
OECD ,
Passive Foreign Investment Company ,
Pillar 2 ,
Reorganizations ,
Research and Development ,
Tax Credits ,
Tax Legislation ,
Tax Liability ,
Tax Litigation ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Virtual Currency
Efficiently executing a cross-border transaction requires experience, pragmatism and a specialized skill set. We have closed transactions in more than 75 countries for buyers and sellers across the full spectrum of...more
The exclusion for gain on qualified small business stock (QSBS) under Section 1202 has garnered increasing attention in recent years. With little administrative guidance from the Internal Revenue Service, investors and owners...more
A panel of the US Court of Appeals for the Federal Circuit considered whether the Patent Commissioner, on assuming the role of the US Patent & Trademark Office (PTO) Director, can constitutionally evaluate the rehearing of...more
6/2/2022
/ America Invents Act ,
Appeals ,
Appointments Clause ,
Constitutional Challenges ,
Inter Partes Review (IPR) Proceeding ,
Obviousness ,
Patent Litigation ,
Patent Trial and Appeal Board ,
Patents ,
Principle Officers ,
Prior Art ,
Priority Patent Claims ,
USPTO
On May 28, 2021, the US Department of the Treasury (Treasury) released the Fiscal Year (FY) 2022 budget and Green Book, which provides detailed insights into the proposals of US President Joe Biden’s recently released...more
6/22/2021
/ Anti-Inversion Regulations ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Biden Administration ,
Country-by-Country ,
Federal Budget ,
Fiscal Year ,
Foreign Tax Credits ,
GILTI tax ,
Green Book ,
International Tax Issues ,
IRS ,
Subpart F ,
Tax Incentives ,
U.S. Treasury
The list of Internal Revenue Service (IRS) forms that can be digitally signed continues to grow. On August 28, 2020, the IRS issued a memorandum indicating that it would accept the use of digital signatures on various IRS...more
On September 1, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released final regulations on the base erosion and anti-abuse tax (the BEAT) under section 59A. These regulations finalize...more
On July 9, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released Final Regulations (Final Regulations) that provide guidance on the section 250 deduction for foreign-derived intangible...more
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
New IRS guidance takes the position that taxpayers may not deduct payroll, mortgage interest, rent or utility expenses that were paid with PPP loan proceeds. The guidance also confirms that forgiven PPP loans will not be...more
The President signed into law the CARES Act to provide tax relief, cash flow, and liquidity to businesses along with benefits to individuals. Learn how these changes will impact your business...more
4/2/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Employee Retention ,
Financial Stimulus ,
Net Operating Losses ,
Pass-Through Entities ,
Payroll Taxes ,
Property Improvements ,
Relief Measures ,
Self-Employment Tax ,
Tax Credits
Covid-19 is creating unexpected tax exposure for foreign-based businesses with employees detained in the US and vice versa as companies may now find themselves with more sourced income than expected causing unforeseen tax...more
The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more
1/29/2020
/ Capital Gains ,
Community Development ,
Economic Development ,
Estate Planning ,
Final Rules ,
FIRPTA ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Partnerships ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Exempt Entities ,
Tax Planning ,
Trusts ,
U.S. Treasury
Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more
12/18/2019
/ Anti-Abuse Rule ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Business Judgment Rule ,
Corporate Taxes ,
Final Rules ,
GILTI tax ,
Income Taxes ,
IRS ,
New Regulations ,
Popular ,
Proposed Regulation ,
Revenue Procedures ,
Subpart F ,
Treasury Regulations
After nearly a decade of being put on hold, several members of the Senate Foreign Relations Committee have recently indicated that the first US-Chile Income Tax Treaty is expected to be approved by the end of the year. The...more
The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more
5/3/2019
/ Anti-Abuse Rule ,
Capital Gains ,
Community Development ,
Debt Financing ,
Economic Development ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Low Income Housing ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Safe Harbors ,
Tangible Property ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning ,
U.S. Treasury
The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions as an incentive for taxpayer investment in low-income neighborhoods and combined the benefits of both tax deferral and tax elimination. On October 19,...more
Health Care Private Equity Investments in India -
A flurry of recent private equity (PE) investments in the Indian health care sector demonstrates strong investor appetite and opportunities.
India is one of the fastest...more
The Tax Cuts and Jobs Act introduced an important new benefit to US corporations that own 10 percent or more of a foreign corporation. Specifically, a full participation exemption has been enacted that exempts certain foreign...more
6/19/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
Tax Reform