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
Beginning January 1, 2024, many types of legal entities must report information regarding their “beneficial owners” and certain other information (collectively, “BOI”) to the Financial Crimes Enforcement Network (“FinCEN”)....more
State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. In this newsletter edition, we will briefly summarize certain SALT developments in several...more
...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of May 3 – May 7, 2021 - Chancellor v. Comm’r, T.C. Memo....more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
“The board is set. The pieces are moving. We come to it at last.” With these words, Gandalf the White acknowledged that the decisive battle for control over Middle Earth had been joined. So it is now for the U.S....more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more
The new regulations proposed in September under Section 382(h) regarding built-in-gain raise several international tax issues that companies planning for post-acquisition integration of loss corporations should be aware of....more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6 – 10, 2019. May 7, 2019: The IRS released Revenue Procedure 2019-22 updating Revenue...more
As discussed, the IRS’s initial interpretation of a new excise tax under Section 4960 of the Internal Revenue Code could catch for-profit employers who set up foundations, trusts, PACs, and other tax-exempt entities off...more
• The Internal Revenue Service (IRS) released IRS Notice 2019-09 (Notice) offering guidance under Section 4960 of the Internal Revenue Code as added by the Tax Cuts and Jobs Act. • Section 4960 applies to certain...more
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
Until the issuance of the Proposed Regulations described below, under Section 956 of the Internal Revenue Code of 1986 (IRC) and Treasury Regulations thereunder, deemed dividends were potentially created when a U.S. borrower...more
The “deemed dividend” rule, the source of much wrangling between multi-national borrowers and lenders over the years, may be on its way out....more
On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of the Internal Revenue Code of...more
On July 31, the Alabama Department of Revenue (ADOR) released its long-awaited “Analysis of Federal Tax Law Revisions on the State of Alabama,” a comprehensive review of the changes brought about by the Tax Cuts and Jobs Act...more
• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more
On April 11, 2018, the General Assembly’s Revenue Laws Study Committee released a draft tax bill for possible introduction in the legislative session that convenes May 16. This Alert provides a summary of the more important...more
The Administration’s frenzy to pass “tax reform” created tax breaks for some—I’m looking at you, the Trump family—increased taxes for others, and confusion for everyone, at least until the IRS is able to promulgate official...more
The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more