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Navigating Tariffs and Income Taxes and Transfer Pricing

In this new trade landscape, it is more important than ever to coordinate customs and operational planning with income taxes and transfer pricing....more

New Proposed Regulations Address Spin-Off Transactions

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

IRS Updates Fast-Track Program for Certain Corporate Tax Rulings

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

New Fast-Track IRS Guidance for Spin-Offs and Other Corporate Transactions

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

Blockchain and Tax: Navigating Uncertainty

Virtual currencies (often called cryptocurrencies) such as bitcoin are perhaps blockchain's best-known application. As these and other blockchain-based digital assets become more common, and attract more regulatory and...more

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