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Corporate Taxes › Section 482 › Internal Revenue Service

Morgan Lewis

IRS’s Implicit Parental Support Guidance ‘Formalizes’ Past Litigation Position

Morgan Lewis on

The Internal Revenue Service (IRS) recently issued a nonbinding Generic Legal Advice Memorandum (GLAM) that provides advice on Internal Revenue Code Section 482 and so-called implicit parental support. Consistent with prior...more

McDermott Will & Emery

Focus on Tax Strategies & Developments - October 2015

McDermott Will & Emery on

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

Pillsbury Winthrop Shaw Pittman LLP

Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

Pillsbury Winthrop Shaw Pittman LLP on

The Stunning Altera Case - Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more

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