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
These proposed regulations applicable to tax-free spin-offs would impose a range of new substantive requirements and greatly expand the information that must be reported to the Internal Revenue Service ("IRS") by taxpayers...more
1/24/2025
/ Corporate Taxes ,
Filing Requirements ,
Internal Revenue Code (IRC) ,
IRS ,
NPRM ,
Proposed Regulation ,
Reporting Requirements ,
Spinoffs ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Tax-Free Spin-Offs
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
The Background: The U.S. Treasury Department ("Treasury") issued regulations finalizing the reporting requirements on the 1% corporate stock buyback tax and starting the clock on the tax's first filing and payment deadline....more
A new program offers rulings in 12 weeks, even absent a showing of business need.
Revenue Procedure 2023-26, issued July 26, 2023, in replacement of a popular 18-month pilot program under Revenue Procedure 2022-10,...more
8/3/2023
/ Annual Filings ,
Corporate Taxes ,
Fast Track Process ,
Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Revenue Procedures ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Time Extensions ,
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
On January 14, 2022, the Internal Revenue Service ("IRS") released Revenue Procedure 2022-10, which establishes a "fast-track processing" pilot program for certain private letter ruling requests that are solely or primarily...more
Current Status: The UK Government is moving ahead with its implementation of the Digital Services Tax ("DST") despite concerns raised by the United States and the Organisation of Economic Co-operation and Development ("OECD")...more