On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more
1/6/2020
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Final Rules ,
Foreign Earned Income ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
Proposed Regulation ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Planning ,
U.S. Treasury
On October 9, 2019, the IRS released Revenue Ruling 2019-24, which provides guidance with respect to hard forks and airdrops of cryptocurrency, and new frequently asked questions (FAQs), which provide guidance on other...more
10/14/2019
/ 1099s ,
Blockchain ,
Capital Gains ,
Cryptocurrency ,
Distributed Ledger Technology (DLT) ,
Fair Market Value ,
Income Taxes ,
IRS ,
New Guidance ,
Peer-to-Peer ,
Popular ,
Revenue Rulings ,
Transfer Taxes ,
Virtual Currency ,
W-2
Introduction -
U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury are still figuring out the details of how...more
7/11/2018
/ Copyright ,
Foreign Derived Intangible Income (FDII) ,
Foreign Earned Income ,
Foreign Subsidiaries ,
Franchises ,
GILTI tax ,
Income Taxes ,
IRS ,
New Rules ,
Patents ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Incentives ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trademarks ,
Transfer Taxes ,
U.S. Treasury
In This Issue -
US Taxation of IP After Tax Reform -
U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury...more
7/11/2018
/ America Invents Act ,
Appeals ,
Artists ,
Claim Construction ,
Copyright ,
Copyright Infringement ,
Defend Trade Secrets Act (DTSA) ,
Disgorgement ,
Evidence ,
Expert Testimony ,
Fair Use ,
Film Industry ,
Foreign Derived Intangible Income (FDII) ,
Franchises ,
Income Taxes ,
Indefiniteness ,
Injunctive Relief ,
Intellectual Property Litigation ,
Intellectual Property Protection ,
Inter Partes Review (IPR) Proceeding ,
IRS ,
Misappropriation ,
New Rules ,
Patent Infringement ,
Patent Litigation ,
Patent Royalties ,
Patent Trial and Appeal Board ,
Patents ,
Phillips Standard ,
Popular ,
SAS Institute Inc. v Iancu ,
SCOTUS ,
Summary Judgment ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Reform ,
The Copyright Act ,
Trade Secrets ,
Trademark Litigation ,
Trademarks ,
Transfer Taxes ,
U.S. Treasury ,
Uniform Trade Secrets Acts ,
USPTO
This document discusses Notice 2018-26, the third IRS Notice providing guidance on the new mandatory repatriation tax under ยง 965.
Most importantly, the Notice sets forth extensive anti-avoidance rules in respect of...more