The Inflation Reduction Act of 2022 (the “IRA”) released by U.S. Senate Democrats on July 27, 2022 would, if enacted, provide a number of financial incentives to encourage the purchase of electric and hydrogen fuel cell...more
Against the backdrop of rapidly evolving blockchain technology, the IRS has oftentimes been slow to update its related tax guidance, leaving participants in the blockchain ecosystem uncertain about their tax obligations....more
The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more
6/21/2019
/ Advanced Pricing Agreements ,
Business Entities ,
Corporate Counsel ,
Corporate Taxes ,
Cost-Sharing ,
Income Taxes ,
Intangible Property ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Multinationals ,
Offshore Companies ,
Section 482 ,
Stock-Based Compensation ,
Tax Court
Congress has passed the tax reform bill, known as the “Tax Cuts and Jobs Act” (the “Act”), and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law, many of which will...more
2/2/2018
/ Bonus Depreciation ,
Carried Interest Tax Rates ,
Compensation & Benefits ,
Corporate Taxes ,
EBITDA ,
Executive Compensation ,
Income Taxes ,
Net Operating Losses ,
New Legislation ,
Partnership Interests ,
Pass-Through Entities ,
Portfolio Companies ,
Private Equity Funds ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
On December 15, the U.S. Congress issued its final version of tax reform via the Conference Report Bill (the “Bill”), which was passed by both Houses of Congress. The Bill represents a compromise of two prior tax reform ...more
12/29/2017
/ Alternative Minimum Tax ,
Base Erosion Tax ,
Business Taxes ,
Corporate Taxes ,
Foreign Tax Credits ,
Income Taxes ,
International Tax Issues ,
Legitimate Business Interest ,
New Legislation ,
Pass-Through Entities ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Deferral ,
Tax Rates ,
Tax Reform ,
Trump Administration
The Paris administrative court ruled on July 12th, 2017, that Google Ireland Limited did not have to pay $1.3 billion in back taxes in France for the period 2005-2010.
The Irish company Google Ireland Limited sells digital...more
9/12/2017
/ BEPS ,
Corporate Taxes ,
Double Taxation ,
France ,
Google ,
Income Taxes ,
Ireland ,
Multilateral Agreement ,
OECD ,
Tax Treaty ,
Value-Added Tax (VAT) ,
Withholding Tax
Last week, the Internal Revenue Service and Treasury Department announced a number of new regulations intended to make it more difficult to qualify for tax advantages associated with inversion transactions and reduce certain...more