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
The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more
UPDATE: The Senate Finance Committee last night released a revised version of the Chairman’s Mark of the Tax Cuts and Jobs Act. We are reviewing these changes and will release an update soon... On Thursday, November 9, the...more
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
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