News & Analysis as of

Corporate Taxes Stocks Tax Planning

Brownstein Hyatt Farber Schreck

Interim Guidance on Book-Minimum Tax and Stock Buyback Excise Tax

The Treasury Department and the Internal Revenue Service (IRS) released initial guidance on Dec. 27, 2022, concerning two corporate tax increases included in the climate and energy reconciliation bill commonly known as the...more

Farrell Fritz, P.C.

Sale Of Stock + Target’s Capitalized Costs = Creation Of Intangible? Nope

Farrell Fritz, P.C. on

Sale of Stock- Ask a business owner to identify the parties to an agreement for the purchase and sale of the stock of a target corporation, perhaps even their own. After giving you a quizzical look, they will likely reply...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

Fenwick & West LLP

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

Coblentz Patch Duffy & Bass

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

Fenwick & West LLP

Section 385 Proposed Regulations

Fenwick & West LLP on

On April 4, 2016, Treasury and the IRS proposed sweeping regulations under § 385 of the Code. Issued the same day as the anti-inversion temporary regulations, the proposed § 385 rules would go much farther than merely...more

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