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Federal Taxes International Tax Issues

A&O Shearman

Notice 2024-16 Announces Limited Guidance Under Section 961(c)

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On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the...more

McDermott Will & Emery

[Event] 2022 TAX IN THE CITY® CHICAGO: A WOMEN’S TAX ROUNDTABLE - December 6th, Chicago, IL

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Mark your calendars to join us for our year-in-review program that will cover key tax and employee benefits issues affecting the state and local, federal and international legal landscape. We will conclude our program with...more

Miller Nash LLP

A Non-U.S. Company’s Guide To Doing Business in the U.S.: Understanding Federal Taxes

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The global economy is becoming increasingly integrated, and companies are routinely able to access markets throughout the world. For decades, the United States has maintained a robust economy and a strong market for imported...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, March 1, 2022

TAX TIDBIT - State of the Union Look Ahead. President Joe Biden will make his first State of the Union address tonight before a joint session of Congress. As of this writing, the speech has not been made available to the...more

McDermott Will & Emery

[Webinar] Tax in the City® - March 1st, 11:30 am - 1:00 pm PDT

The potential impact of global mobility issues and recent tax developments may require reassessing your planning strategies. Join us for our first Tax in the City® program of 2022, which will cover federal and...more

Miller Nash LLP

Today in Tax: Financial Contract Modification and Foreign Tax Credits

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Transition rules allow opportunity to avoid taxable income when modifying financial contracts from IBOR to another metric Contracts dependent on a discontinued interbank offered rate (“IBOR”) will need to transition to an...more

McDermott Will & Emery

[Webinar] Tax in the City® - November 2nd, 11:30 am - 1:00 pm PDT

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Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape. Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more

McDermott Will & Emery

[Webinar] Tax in the City®: San Francisco - May 18th, 1:00 pm - 2:30 pm PDT

Please join us for our inaugural Tax in the City® in San Francisco—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and confidential setting. Our...more

Freeman Law

International Tax Treaty: Australia

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Quick Summary. Located “down under” in the Southern Hemisphere and covering the Indian and Pacific Oceans, Australia consists of a mainland continent, the island of Tasmania, and several smaller islands. Australia comprises...more

McDermott Will & Emery

[Event] West Coast Tax Forum: California & Beyond: The Impact Of State, Federal And International Tax Developments On Golden State...

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Tax professionals are on the frontlines, responding to state, federal and international tax developments that significantly impact business objectives. California taxpayers face particularly unique challenges. Join members...more

Fenwick & West LLP

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

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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

Eversheds Sutherland (US) LLP

Much ado about nothing - IRS provides advance payments guidance with release of Notice 2018-35

On April 12, 2018, the Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-35 (Notice) that provides transitional guidance relating to advance payments under Rev. Proc. 2004-34. Despite the...more

McDermott Will & Emery

Connecticut Responds to the Federal Repatriation Tax

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Earlier this month, Connecticut Governor Dan Malloy released his Governor’s Bill addressing the various state tax implications of the federal tax reform bill enacted by Congress in December 2017, commonly referred to as the...more

Cozen O'Connor

Federal Tax Legislation: Major Changes to International Taxation

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On December 22, 2017, President Trump signed into law a comprehensive tax reform bill commonly known as the Tax Cuts and Jobs Act (the Act). The Act makes major changes to federal income and estate tax law, including numerous...more

McDermott Will & Emery

State and Local Tax Aspects of Republican Tax Reform Framework

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The White House and Republican congressional leadership released an outline this week to guide forthcoming legislation on federal tax reform. The states conform to the federal tax laws to varying degrees and the extent to...more

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