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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

Supreme Court Upholds the Mandatory Repatriation Tax in Moore v. United States

The U.S. Supreme Court has affirmed the Ninth Circuit's decision in Moore v. United States, upholding the constitutionality of the mandatory repatriation tax enacted in 2017....more

Internal Revenue Service Alters Its View on Section 355 Spin-Offs

The Internal Revenue Service ("IRS") recently issued important guidance identifying new positions the IRS is considering on critical aspects of tax-free spin-offs, and significantly expanding the information that taxpayers...more

District of Columbia Expands False Claims Act to Include Qui Tam Tax Fraud Actions

The enforcement of the District's tax laws had previously been left exclusively to government agencies; a newly enacted bill will make the District one of a few jurisdictions to allow relators to bring qui tam suits alleging...more

U.S. Tax Reform Proposal Highlights Potential Sweeping Changes

The Situation: The Trump Administration, in collaboration with the House and Senate, has introduced a Framework for tax reform legislation that could bring sweeping changes to U.S. tax laws....more

Trump Administration Proposes Tax Reductions

On April 26, 2017, the Trump Administration officially announced the President's tax reform plan in a one-page proposal calling for substantial business and individual tax cuts and the elimination of the AMT and many...more

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