Introduction On August 16, President Biden signed into law the Inflation Reduction Act of 2022, P.L. 117-169 (IRA). The law addresses a range of issues, from climate change to energy security to prescription drug prices for...more
In a ruling with tax implications for U.S. corporations with foreign subsidiaries, the U.S. Tax Court has held that transactions between a U.S. parent company and its controlled foreign corporations constitute “United States...more