Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
How Tax Works - Entity Selection
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Spotlight Series: Beyond the Technical Side of Tax Law
10 Things Lawyers Should Know About BVI Transactions
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
The Biden Tax Plan
Tax Planning Under a Biden Presidency
2020 Presidential Candidates' Tax Proposals
New anti-abuse provisions
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Impact of environmental, social and governance agenda on tax
We have been waiting several months for the Supreme Court of the United States (SCOTUS) to render a decision in Moore v. United States. Initially, our questions focused on the issue of “realized or unrealized income” and...more
On June 20, 2024, the U.S. Supreme Court issued its long-anticipated decision in Moore v. United States, in which a 7-2 majority upheld the constitutionality of the mandatory repatriation tax (“MRT”) under section 965 of the...more
On June 20, 2024, the Supreme Court released its opinion in Moore et ux v. US, authored by Kavanaugh, decided by 6-3 vote and marking a rare instance for the Court to interpret the 16th Amendment, upholding the...more
The Tax Cuts and Jobs Act of 2017 amended the law to introduce a new, one-time, mandatory repatriation tax on trillions of dollars of accumulations held abroad by American-controlled foreign entities. The tax is imposed on...more
The Supreme Court of the United States issued four decisions today: Moore v. United States, No. 22-800: This case concerns the constitutionality of the Mandatory Repatriation Tax (“MRT”) included in the 2017 Tax Cuts and...more
The U.S. Supreme Court today upheld the constitutionality of the so-called “mandatory repatriation tax” in a narrow ruling, stating that the MRT taxes realized income — income earned by the offshore corporation — and...more
Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more
The Supreme Court granted certiorari on June 26 with respect to the Ninth Circuit’s decision in Moore v. United States. The question presented is whether the section 965 transition tax is a “direct tax” that violates the...more
SCOTUS Denies New York v. Yellen. The U.S. Supreme Court announced on Tax Day it would not hear a constitutional challenge to the $10,000 deduction limit on state and local taxes (SALT) enacted under the Tax Cuts and Jobs Act...more
Back at it. Let’s get caught up . . . Treasury Secretary Janet Yellen is calling for a global minimum tax rate on multinational corporations, a move aimed at helping “prevent companies based in other countries from having a...more
Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more
Germany’s diesel emissions scandal bears a lot of resemblances to the Wells Fargo debacle here at home. It just can’t seem to quit itself. This week, we’ve learned that German authorities have opened a criminal inquiry into...more
The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast....more
Today, the U.S. Supreme Court vacated the decision of the Massachusetts Supreme Judicial Court (SJC) in First Marblehead Corp. v. Commissioner of Revenue (First Marblehead) and remanded the case back to the court for...more
Under the Dome: Inside the Maine State House provides a high-level overview of recent activity at the Maine State House. Legislature Plans Long Day - Early this past Wednesday morning, the Maine House and Senate...more
In Comptroller of the Treasury of Maryland v. Wynne, Dkt. No. 13-485 (U.S. May 18, 2015), the U.S. Supreme Court found that Maryland’s system of personal income taxation violated the nondiscrimination prong of the dormant...more
On May 18, 2015, the U.S. Supreme Court decided Comptroller of the Treasury of Maryland v. Wynne, No. 13-485, holding that the absence of a credit against the local portion of the state’s personal income tax scheme was an...more
On March 4, 2015, the Supreme Court decided Alabama Department of Revenue v. CSX Transportation, Inc., No. 13-553, holding that a rail carrier can prove discrimination under the Railroad Revitalization and Regulation Reform...more
On December 9, the U.S. Supreme Court heard oral arguments in the last of three state and local tax cases that it accepted this term – Alabama Department of Revenue v. CSX Transportation, Inc. (CSX II), a case that had...more
On June 19, 2014, the United States Supreme Court held that a taxpayer has the right to examine Internal Revenue Service (IRS) officials regarding their reasons for issuing a summons only if the taxpayer points to facts or...more
I. A Look Back At 2013 Tax Matters, “Gangnam Style” - A. Some Random Observations. - 1. When we penned last year’s Update for you, dear reader, this fair country of ours stood six feet from the edge of the “...more