With the release of its FY 2022 revenue proposals, the Biden Administration explains and refines some of the tax priorities raised on the campaign trail. Our International Tax Group reads the tea leaves to find the...more
The Tax Cuts and Jobs Act of 2017 continues to reverberate even unto the end of 2020. Our International Tax Group discusses a letter ruling that may have been a harbinger of proposed regulations to address exceptions to...more
Is your inventory sales income U.S. or foreign source? Well, it depends. Our International Tax Group explores the various sourcing rules the IRS has proposed to sort out possible inconsistencies and overlaps caused by the Tax...more
Tucked away in the recently enacted Tax Cuts and Jobs Act is a provision dealing specifically with S corporations. It is one of these particular provisions that caused the Internal Revenue Service to recently issue a notice...more
At long last, we have the first set of final regulations for the Tax Cuts and Jobs Act. Our International Tax Group celebrates with a look at how the Treasury and IRS have clarified Section 965 and why taxpayers may need to...more
In long-awaited guidance on Section 163(j) post-tax reform, the Treasury and IRS present taxpayers with an expansive definition of “interest,” subjective anti-abuse rules, complex computational instructions, and several...more
The Tax Cuts and Jobs Act replaced the earnings stripping rules with a new limitation on deductions for business interest expense. Our International Tax Group examines the new law and what it means for interest expense...more
The Tax Cuts and Jobs Act, signed into law on December 22, 2017, represents the biggest change to U.S. tax law since adoption of the 1986 Code. In addition to rate cuts and various individual and corporate reforms, the Act...more