Summary -
On November 28, the Tax Court, granting the Internal Revenue Service (IRS) summary judgment, held in Soroban Capital Partners LP v. Commissioner that a state law limited partner who is limited in name only, is...more
In Notice 2020-18, released on March 25, the Department of the Treasury announced that any person with a federal income tax payment or federal income tax return due on April 15, 2020 has until July 15, 2020 to make the...more
Until recently, the structuring of debt facilities for U.S. borrowers with foreign subsidiaries has been largely driven by IRS interpretations of section 956 of the Internal Revenue Code, which gave rise to significant tax...more
5/8/2019
/ C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Credit Facilities ,
Creditors ,
Dividends ,
IRS ,
New Rules ,
Proposed Regulation ,
Section 956 ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning
As the Tax Section celebrates its 75th anniversary, I was asked to reflect on the Section’s contribution in the international tax arena and on how the Section’s international community has grown. I started by recognizing the...more
5/12/2015
/ Cross-Border Transactions ,
FATCA ,
Foreign Taxpayers ,
International Tax Issues ,
OECD ,
Subpart F ,
Tax Credits ,
Tax Planning ,
Tax Policy ,
Tax Reform ,
Transfer Pricing