Our Tax Group reviews how the U.S. Supreme Court’s ruling in Loper Bright that overturned many decades of the Chevron doctrine will affect federal and state taxes....more
Our Federal & International Tax Group examines a long-awaited Tax Court ruling that helps clarify when a non-U.S. company engages in a “U.S. trade or business.”...more
The potential complexities surrounding pass-through entity tax elections might make you cry, but the potential tax benefits won’t make you blue. Our Federal Tax Group examines how PTET elections have become an important...more
Carbon capture and storage could play a major role in a Biden Administration eager to rejoin the Paris Agreement. Our Federal Tax Group provides a brief overview of the 45Q credit and key takeaways from the IRS’s new final...more
What does a (barely) Democratic Senate mean for Biden’s tax plans? Our International Tax Group discusses the President-elect’s broad proposals and how they could change the cross-border tax landscape....more
The CARES Act’s Paycheck Protection Program (PPP) was a boon to many businesses, but some of its particularities have become a headache to acquiring taxpayers. Our Federal Tax Group untangles how PPP loans affect employee...more
Our Federal Tax Group explains new IRS relief that permits partnerships to file amended returns for their 2018 and 2019 taxable years to claim the benefit of retroactive provisions in the Coronavirus Aid, Relief, and Economic...more
Our International Tax Group addresses an election under Section 962 available to individual U.S. shareholders of certain foreign corporations to be taxed as a C corporation, which before tax reform was a rarely utilized and...more
At long last, we have the first set of final regulations for the Tax Cuts and Jobs Act. Our International Tax Group celebrates with a look at how the Treasury and IRS have clarified Section 965 and why taxpayers may need to...more
The Tax Cuts and Jobs Act, signed into law on December 22, 2017, represents the biggest change to U.S. tax law since adoption of the 1986 Code. In addition to rate cuts and various individual and corporate reforms, the Act...more
With tax reform on the horizon, Treasury takes aim at three sets of regulations with clear cross-border implications. Our International Tax Group explains the department’s recommendations to scrap much of Section 385 and...more
Tax reform is coming, and Republican leaders have published a framework that raises as many questions as it answers. Our Tax Policy & Regulation Team investigates what the Big Six reveal and—just as important—what they don’t....more
A foreign investor, not engaged in a U.S. trade or business, can sell stock in a U.S. corporation without fear of U.S. tax liability (with the notable exception of stock in certain U.S. corporations heavily invested in U.S....more
On February 23, 2016, the Internal Revenue Service (IRS) released proposed regulations providing guidance on the definition of a “political subdivision” under the tax-exempt bond rules. A public hearing is scheduled for June...more
LTR 201542004 at first seems to involve a standard spinoff for the purpose of pursuing a reverse Morris Trust combination of Controlled with a Merger Partner, with the “significant issue” for ruling being a proposed swap of...more