In 2016, the Obama administration issued a series of rules and regulations designed to stem the flow of corporate inversions – transactions where U.S. corporations moved offshore to avoid the high 35% U.S. corporate tax rate....more
Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct. On August 6, 2018, the US Tax Court decided...more
Earlier this year, President Trump issued Executive Order 13789, which ordered the Treasury Department to review all significant tax regulations issued after December 31, 2015 and identify regulations that impose an undue...more
On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more