On August 7, 2022, the US Senate passed the Inflation Reduction Act of 2022 (the Act), a budget reconciliation bill recently introduced by Senate Majority Leader Chuck Schumer (D-NY) and Senator Joe Manchin (D-WV). The bill...more
On May 28, 2021, the US Department of the Treasury (Treasury) released the Fiscal Year (FY) 2022 budget and Green Book, which provides detailed insights into the proposals of US President Joe Biden’s recently released...more
6/22/2021
/ Anti-Inversion Regulations ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Biden Administration ,
Country-by-Country ,
Federal Budget ,
Fiscal Year ,
Foreign Tax Credits ,
GILTI tax ,
Green Book ,
International Tax Issues ,
IRS ,
Subpart F ,
Tax Incentives ,
U.S. Treasury
The final debt-equity regulations issued on May 13, 2020, finalize proposed section 385 regulations issued in 2016 without any substantive changes to the existing debt-equity regulations, and withdraw the temporary section...more
On April 24, 2020, the US Court of Appeals for the Eighth Circuit published its opinion in Wells Fargo & Co. v. United States, No. 17-3578, affirming a district court’s holdings that the taxpayer was not entitled to certain...more
On April 14, 2020, the Internal Revenue Service (IRS) issued informal guidance in the form of frequently asked questions (the “FAQs”), urging taxpayers to strengthen their transfer pricing documentation required under...more
While much of the focus on tax reform has been the interpretation and implementation of the newly adopted rules, it is also worth considering how the changes adopted in tax reform have given new life to some preexisting...more