The US Department of the Treasury and the Internal Revenue Service (IRS) recently issued Notice 2025-44, announcing their intent to withdraw the controversial disregarded payment loss (DPL) rules finalized at the end of the...more
8/28/2025
/ Comment Period ,
Corporate Taxes ,
Final Rules ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Guidance ,
OECD ,
Proposed Rules ,
Regulatory Reform ,
Tax Planning ,
U.S. Treasury
Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more
3/11/2025
/ Compliance ,
Corporate Taxes ,
Final Rules ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Regulatory Requirements ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
Taxpayers have been eagerly awaiting, and the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have been promising to provide, rules addressing the previously taxed earnings and profits (PTEP)...more
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
5/2/2024
/ Acquisitions ,
Best Practices ,
Continuing Legal Education ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Corporate Transparency Act ,
Cross-Border ,
Digital Advertising Tax ,
Digital Goods ,
Energy Tax Incentives ,
Events ,
Family Offices ,
Federal Taxes ,
Foreign Assets ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
Income Taxes ,
Internet Tax Freedom Act ,
IRS ,
Mergers ,
Multinationals ,
OECD ,
Passive Foreign Investment Company ,
Pillar 2 ,
Reorganizations ,
Research and Development ,
Tax Credits ,
Tax Legislation ,
Tax Liability ,
Tax Litigation ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Virtual Currency
Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape.
Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more
10/21/2021
/ Business Taxes ,
Continuing Legal Education ,
Corporate Taxes ,
Federal Taxes ,
Income Taxes ,
International Tax Issues ,
IRS ,
Local Taxes ,
Multinationals ,
Partnerships ,
Proposed Legislation ,
SALT ,
State Taxes ,
Tax Legislation ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Webinars
Please join us for our inaugural Tax in the City® in San Francisco—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and confidential setting.
Our...more
5/4/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Continuing Legal Education ,
Federal Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
OECD ,
Partnerships ,
State Taxes ,
Tax Planning ,
Webinars
We invite you to join us for a discussion on current tax issues including:
• Judicial deference and potential impact on TCJA audits
• Developments and planning considerations for intangible assets
o US tax...more
9/25/2019
/ Asset Management ,
Continuing Legal Education ,
EU ,
Events ,
Income Taxes ,
Intangible Property ,
International Tax Issues ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
UK Brexit
Income from the sale of inventory by a domestic corporation generally is sourced based on where title and risk of loss to the property pass to the buyer. Thus, income from the sale of inventory where title passes outside the...more