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
With the emergence of digital assets, the question has arisen whether digital assets held in “wallets” in foreign exchanges need to be reported on Internal Revenue Service (IRS) Form 8938, Statement of Specified Foreign...more
1/8/2020
/ Bitcoin ,
Commodities ,
Cryptocurrency ,
Currency Exchange ,
Digital Assets ,
Digital Currency ,
Digital Securities ,
Digital Wallets ,
FATCA ,
FBAR ,
Filing Requirements ,
Foreign Assets ,
Foreign Exchanges ,
Foreign Financial Assets ,
Foreign Financial Institutions (FFI) ,
HIRE Act ,
Investment ,
IRS ,
Money Services Business ,
Popular ,
Regulatory Requirements ,
Reporting Requirements ,
Required Forms ,
Rulemaking Process ,
Tax Liability ,
Virtual Currency
Code section 965 establishes a transition tax (the “Transition Tax”), which applies to U.S. corporations (and in certain cases, U.S. partnerships and individuals) having control over unrepatriated offshore earnings as of the...more
On July 24, 2018, in the Altera Corp v. Commissioner decision, the Ninth Circuit overturned a 2015 U.S. Tax Court opinion and upheld the validity of regulations requiring taxpayers to treat stock-based compensation as a cost...more
8/3/2018
/ Arms Length Transactions ,
Compensation & Benefits ,
Corporate Taxes ,
Cost-Sharing ,
Foreign Corporations ,
IRS ,
Multinationals ,
Stock-Based Compensation ,
Tax Liability ,
Tax Planning ,
Technology Sector ,
Transfer Pricing
In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more
3/3/2017
/ AbbVie ,
Capital Losses ,
Inversion ,
IRS ,
Offshore Companies ,
Pharmaceutical Industry ,
Shareholder Votes ,
Stocks ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Termination Payments
On October 5, 2016, the IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged...more
The Protecting Americans From Tax Hikes Act of 2015 (the "PATH Act"), expected to be soon passed by Congress and signed into law by President Obama, permanently extends the 100% exclusion for gain recognized on the sale of...more
The Protecting Americans From Tax Hikes Act of 2015 (the "PATH Act"), expected to be soon passed by Congress and signed into law by President Obama, permanently extends the 100% exclusion for gain recognized on the sale of...more