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Mayer Brown

TBU | Offset of Taxes Paid Abroad by Controlled and Affiliated Companies – RFB Interpretative Declaratory Act No. 1/2026

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On January 23, 2026, the Brazilian Federal Revenue Service (“RFB”) published Interpretative Declaratory Act (“ADI”) No. 1/2026, which addresses the use of taxes paid abroad by directly or indirectly controlled or affiliated...more

Mayer Brown

Décision du Conseil d’Etat sur l’ordre d’imputation des déficits reportables en avant

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Le Conseil d’Etat tranche la question de l’ordre d’imputation des déficits reportables en avant : il retient une imputation selon un ordre strictement chronologique et en tire les conséquences pour l’application des règles de...more

DLA Piper

Lifecycle of a transaction: tax disputes on intra-group debt

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Where there is potential for a tax dispute, it is crucial to map your position early: proactively building a “defence” file can best prepare taxpayers for HMRC enquiries when they arise years later. Originally Published in...more

Ankura

The Critical Importance of Tax Due Diligence in Modern Business Transactions

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In today's complex and ever-evolving business landscape, tax due diligence has emerged as a critical component of financial analysis and risk management in mergers, acquisitions, and other significant business transactions....more

Vinson & Elkins LLP

[Hybrid Event] The New Corporate AMT and Attorney/Client Privilege: Why Your Attorney Should Hire Your Accountant - January 12th,...

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The new corporate alternative minimum tax (“CAMT”) generally applies to corporations with 3-year average “book” income in excess of $1 billion. Thus whether a corporation owes CAMT may depend on positions taken under GAAP....more

Foodman CPAs & Advisors

High-Income Individuals And Corporate Tax Returns Are Targets Of IRS Additional Funding Program

The 2022 discretionary funding request (request) made by the Biden Administration will invest in a “fair and robust” tax system that includes tax compliance enforcement directed at High Income and High Net  Worth Individuals...more

BakerHostetler

[Podcast] When State Tax Agencies Speak from Both Sides of the Mouth

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In Wisconsin Department of Revenue v. Deere & Company, the Department of Revenue tried to disallow a dividends received deduction for distributions from a Luxembourg entity despite published guidance conflicting with its...more

Buckingham, Doolittle & Burroughs, LLC

Earth-shattering tax liability means doomsday for vendors: Don’t put your personal net worth at-risk

Vendors selling out of state but not collecting sales tax are on a path to suffering severe financial loss. The tax liability could be astronomical – enough to devastate a business – as high as 10% or more of total sales for...more

Bracewell LLP

Bracewell Tax Report: March 2018

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The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more

Schwabe, Williamson & Wyatt PC

CPA Shoptalk: 8 Takeaways

On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more

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