After numerous years in treaty limbo, the US Senate recently provided its advice and consent for ratification of four protocols with Luxembourg, Switzerland, Japan and Spain, setting the stage for the protocols to enter into...more
Public Law 115-97 (the Tax Cuts and Jobs Act (TCJA)) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. On September 13, 2018, the Department of the Treasury...more
9/25/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Shareholders ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On August 1, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations, which were published in the Federal Register on August 9, 2018 (Proposed Regulations),...more
On August 7, 2018, the US Court of Appeals for the Ninth Circuit withdrew its opinion in Altera Corporation v. Commissioner, just 15 days after the initial release of the opinion. The court in Altera had overturned a Tax...more
On July 24, 2018, the US Court of Appeals for the Ninth Circuit in Altera Corporation v. Commissioner overturned a unanimous decision by the Tax Court invalidating Treas. Reg. § 1.482-7A(d)(2), which provides that a...more
8/1/2018
/ Administrative Procedure Act ,
Arm's Length Principle ,
Cost-Sharing ,
Equity Compensation ,
IRS ,
Notice and Comment ,
Stock Options ,
Stock-Based Compensation ,
Subsidiaries ,
Tax Court ,
U.S. Treasury
On July 2, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns, including campaigns relating to virtual currency and the transition tax...more