The 2017 Tax Act significantly increased the benefits of a section 338(g) election for a domestic corporate purchaser of stock in a controlled foreign corporation (CFC). If an election is made, the Buyer is treated as...more
The purpose of section 367(b) in the context of an inbound section 332 liquidation or section 368 reorganization (inbound asset transfer) is to ensure that the domestic acquiring corporation (or domestic shareholder of the...more
Changes made by tax reform have caused companies to reevaluate their structures. This reevaluation extends to the most fundamental decision: choice of entity. The choice of entity decision now frequently hinges on two key,...more
The final US tax legislation includes a number of provisions that will impact the property & casualty (P&C) insurance sector, including captive insurance companies. Specific to the insurance sector are new rules for computing...more
A number of provisions included in the Senate’s tax reform bill, H.R. 1 (the Senate Bill) would impact the insurance sector. Many of the provisions would affect only the life insurance industry. Others affect property &...more