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
Be wary: The US Department of the Treasury’s proposed disregarded payment loss (DPL) regulations lay surprising new traps for multinational taxpayers – and those ensnared are unlikely to see what’s coming.
Under the...more
BACKGROUND: SECTION 367(D) Section 367(d) generally addresses outbound transfers of intangible property to a foreign corporation. It treats a US transferor that transfers intangible property subject to Section 367(d) as...more
CFOs of recently de-SPAC’ed* and newly public companies face significant challenges. High on the list is the recently released Made in America Tax Plan, through which the Biden administration proposed significant changes to...more
5/21/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Biden Administration ,
CFOs ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Green Book ,
Made in the USA ,
Mergers ,
Proposed Regulation ,
Publicly-Traded Companies ,
Special Purpose Acquisition Companies (SPACs) ,
Tax Increases
The Treasury Department and the IRS have issued highly anticipated guidance in the area of stewardship expenses and R&D expenses. The 2019 Proposed Regulations also provide extensive guidance on allocating and apportioning...more
12/20/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Tax Credits ,
IRS ,
New Rules ,
Proposed Regulation ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
U.S. Treasury