On August 7, 2022, the Senate passed a major climate, health and tax bill through the budget reconciliation process. The bill, named the Inflation Reduction Act of 2022, is expected to be taken up by the House of...more
Section 1202 is a once-obscure tax saving provision that has come into prominence in the last few years. Originally passed in 1993 as a 50% capital gain exclusion, it has been amended several times since. In its current...more
Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...more
5/2/2016
/ Affiliates ,
Anti-Inversion Regulations ,
Comment Period ,
Controlled Groups ,
Corporate Taxes ,
Debt ,
IRS ,
Multinationals ,
Parent Corporation ,
Proposed Regulation ,
Related Parties ,
Required Documentation ,
Stocks ,
U.S. Treasury