For US alcohol exporters – whether crafting bourbon, brewing craft beer, or bottling fine wines – selling to international markets is a significant opportunity for growth. Two US federal income tax regimes, the...more
3/5/2025
/ Corporate Taxes ,
Export Controls ,
Exporters ,
Exports ,
Foreign Derived Intangible Income (FDII) ,
Internal Revenue Code (IRC) ,
International Trade ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Wine & Alcohol
Qualified Opportunity Funds (QOFs) offer generous tax incentives but are bound by a complicated set of rules, not to mention the complexity of Subchapter K of the Internal Revenue Code (IRC), as QOFs are typically organized...more
2/3/2025
/ Capital Gains ,
Debt ,
Internal Revenue Code (IRC) ,
Investment ,
Investment Funds ,
IRS ,
Partnerships ,
Qualified Opportunity Funds ,
Tax Credits ,
Tax Incentives ,
Tax Liability ,
Tax Planning
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
In 2013, the net investment income tax (NIIT) found in Internal Revenue Code (IRC) Section 1411 went into effect. Since then, United States taxpayers residing outside of the US have lived with uncertainty as to whether the...more
There has been a growing trend of US taxpayers contributing non-cash assets, such as appreciated property, securities and cryptocurrency, into Maltese pension plans since the US-Malta Tax Treaty went into effect in 2011....more
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, holding that the Internal Revenue Service (IRS) lacked the statutory authority to both assess tax penalties under Internal Revenue Code (Code)...more
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, ruling that the Internal Revenue Service (IRS) could neither assess tax penalties under Internal Revenue Code (Code) Section 6038(b) against Alon...more
Moving to or purchasing real estate in the United States as a nonresident requires careful consideration of US federal income, estate and state and local tax laws. Inbound US federal tax planning involves analyzing these laws...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
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
11/19/2021
/ Capital Gains ,
Claim Limitations ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Safe Harbors ,
Tax Benefits ,
Tax Liability ,
Tax Planning
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
11/12/2021
/ Capital Gains ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Safe Harbors ,
Tax Deferral ,
Tax Liability ,
Tax Planning
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
10/21/2021
/ Business Entities ,
Business Property ,
Capital Gains ,
Eligibility Determination ,
Investment Funds ,
Investors ,
Opportunity Zones ,
Qualified Opportunity Funds ,
REIT ,
REMIC ,
S-Corporation
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
10/21/2021
/ Capital Gains ,
FIRPTA ,
Foreign Investment ,
Investment ,
Investment Funds ,
Investors ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Tax Code ,
Tax Liability
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
CFOs of recently de-SPAC’ed* and newly public companies face significant challenges. High on the list is the recently released Made in America Tax Plan, through which the Biden administration proposed significant changes to...more
5/21/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Biden Administration ,
CFOs ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Green Book ,
Made in the USA ,
Mergers ,
Proposed Regulation ,
Publicly-Traded Companies ,
Special Purpose Acquisition Companies (SPACs) ,
Tax Increases
Although it is unclear what will happen to capital gains rates over the course of the next year, it is important to discuss the implications of what a rate hike could mean. While we don’t know for certain whether the capital...more
An individual or trust US shareholder of a controlled foreign corporation (CFC) faces harsh treatment under the global intangible low-taxed income (GILTI) regime. These tax implications have forced these taxpayers to pursue...more
The US Department of the Treasury and Internal Revenue Service (IRS) recently issued final regulations under section 1446(f), a provision enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA) that generally imposes a...more
The Internal Revenue Service (IRS) ruled that a taxable real estate investment trust (REIT) subsidiary would not be considered to be operating or managing certain senior living and healthcare facilities located outside the...more
As part of its ongoing response to COVID-19, the Internal Revenue Service (IRS) released Notice 2020-49, which extends certain time criteria related to the New Markets Tax Credit (NMTC) program. Under the notice, any due...more
On April 21, 2020, the Internal Revenue Service released an FAQ and two revenue procedures addressing concerns that travel disruptions related to the Coronavirus (COVID-19) pandemic could result in unexpected US tax exposure....more
The CARES Act includes several key benefits for real estate stakeholders as they face the effects of the Coronavirus (COVID-19) pandemic. Many professionals should be able to receive immediate significant tax refunds...more