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 final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more
9/3/2020
/ Continuing Legal Education ,
Controlled Foreign Corporations ,
Exceptions ,
Foreign Affiliates ,
Foreign Earned Income ,
GILTI tax ,
Income Taxes ,
Intangible Property ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
New Regulations ,
Proposed Regulation ,
Subpart F ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Webinars
The Internal Revenue Service (IRS) has issued PMTA 2018-016, reaffirming its position that for taxpayers making an election under Internal Revenue Code (Code) Section 965(h) to pay the transition tax over eight years through...more
We previously discussed the Internal Revenue Service’s (IRS) surprising position that for taxpayers making an election under Internal Revenue Code (Code) Section 965(h) to pay the transition tax over 8 years through...more
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