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State Taxes › Foreign Affiliates

Blank Rome LLP

NY Appellate Court Finds That IBM Cannot Deduct Foreign Royalty Payments

Blank Rome LLP on

A New York intermediate appellate court upheld a New York State Tax Appeals Tribunal determination finding that International Business Machines Corp. and its combined affiliates (together, “IBM”) improperly deducted royalty...more

Sheppard Mullin Richter & Hampton LLP

Congress Passes Final Tax Reform Bill: U.S. Tax Reform: The Current State of Play

Sheppard Mullin Richter & Hampton LLP on

With the affirmative vote in the House today, both Houses of Congress have now passed a final version of the Tax Cuts and Jobs Act, clearing the legislation for President Trump’s signature. President Trump is widely expected...more

Eversheds Sutherland (US) LLP

State Tax Fallout From Federal Proposed Related-Party Debt Regulations

Eversheds Sutherland (US) LLP on

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more

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