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
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 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