In this new trade landscape, it is more important than ever to coordinate customs and operational planning with income taxes and transfer pricing....more
5/22/2025
/ Customs ,
First Sale Doctrine ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Imports ,
Income Taxes ,
Inventory ,
Retail Market ,
Risk Management ,
Suppliers ,
Supply Chain ,
Tariffs ,
Tax Liability ,
Tax Planning ,
Transfer Pricing ,
Trump Administration
The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more
8/30/2024
/ Chevron Deference ,
Corporate Counsel ,
Foreign Subsidiaries ,
Foreign Tax Credits ,
Internal Revenue Code (IRC) ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Regulatory Authority ,
SCOTUS ,
Tax Court ,
Tax Liability ,
U.S. Treasury
In Short -
The Situation: With the Inflation Reduction Act of 2022 (the "IRA"), Congress created new tax credits and expanded several others to encourage U.S. taxpayers to invest in clean energy and carbon reduction...more