Mark your calendars to join us for our year-in-review program that will cover key tax and employee benefits issues affecting the state and local, federal and international legal landscape. We will conclude our program with...more
12/2/2022
/ Compensation & Benefits ,
Employee Benefits ,
Events ,
Federal Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Local Taxes ,
State Taxes ,
Tax Liability ,
Tax Planning
The potential impact of global mobility issues and recent tax developments may require reassessing your planning strategies.
Join us for our first Tax in the City® program of 2022, which will cover federal and...more
2/7/2022
/ Captive Insurance Company ,
Federal Taxes ,
Foreign Tax Credits ,
International Tax Issues ,
Multinationals ,
New Regulations ,
OECD ,
Passive Foreign Investment Company ,
Remote Working ,
Risk Mitigation ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Webinars ,
Women in the Law
Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape.
Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more
10/21/2021
/ Business Taxes ,
Continuing Legal Education ,
Corporate Taxes ,
Federal Taxes ,
Income Taxes ,
International Tax Issues ,
IRS ,
Local Taxes ,
Multinationals ,
Partnerships ,
Proposed Legislation ,
SALT ,
State Taxes ,
Tax Legislation ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Webinars
Please join us for our inaugural Tax in the City® in San Francisco—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and confidential setting.
Our...more
5/4/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Continuing Legal Education ,
Federal Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
OECD ,
Partnerships ,
State Taxes ,
Tax Planning ,
Webinars
What should in-house lawyers spend time discussing with their chief financial officers (CFOs)? What are the most important tax developments affecting businesses today? In this program, we’ll review the key tax issues that...more
4/29/2021
/ Business Taxes ,
Captive Insurance Company ,
CFOs ,
COBRA ,
Continuing Legal Education ,
Contract Renewal ,
Corporate Counsel ,
Insurance Contracts ,
Remote Working ,
Risk Management ,
Risk Mitigation ,
Tax Liability ,
Tax Planning ,
Webinars
An individual or trust US shareholder of a controlled foreign corporation (CFC) faces harsh treatment under the global intangible low-taxed income (GILTI) regime. These tax implications have forced these taxpayers to pursue...more
The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more
9/3/2020
/ Continuing Legal Education ,
Controlled Foreign Corporations ,
Exceptions ,
Foreign Affiliates ,
Foreign Earned Income ,
GILTI tax ,
Income Taxes ,
Intangible Property ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
New Regulations ,
Proposed Regulation ,
Subpart F ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Webinars
We invite you to join us for our Tax in the City®: A Women’s Tax Roundtable in Seattle.
We plan to discuss, among other topics, post-TCJA tax treatment of foreign branches (and disregarded entities), new BEAT guidance, an...more
5/4/2020
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Business Taxes ,
Continuing Legal Education ,
Digital Taxes ,
Economic Presence Nexus ,
Events ,
Foreign Corporations ,
Income Taxes ,
International Tax Issues ,
OECD ,
Out-of-State Companies ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning
Mark your calendars for our spring 2020 Tax in the City®: A Women’s Tax Roundtable in Seattle—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and...more
2/19/2020
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Business Taxes ,
Continuing Legal Education ,
Digital Taxes ,
Economic Presence Nexus ,
Events ,
Foreign Corporations ,
Income Taxes ,
International Tax Issues ,
OECD ,
Out-of-State Companies ,
State Taxes ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning
We invite you to join us for our annual “Year in Review” Tax in the City® Chicago. We will discuss current tax issues including:
• Judicial deference and potential impact on TCJA audits
• Taxation of the digitalized...more
11/27/2019
/ Continuing Legal Education ,
Digital Assets ,
Events ,
Income Taxes ,
International Tax Issues ,
Judicial Deference ,
New Guidance ,
State Taxes ,
Tax Audits ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Litigation ,
Tax Planning
We invite you to join us for a discussion on current tax issues including:
• Judicial deference and potential impact on TCJA audits
• Developments and planning considerations for intangible assets
o US tax...more
9/25/2019
/ Asset Management ,
Continuing Legal Education ,
EU ,
Events ,
Income Taxes ,
Intangible Property ,
International Tax Issues ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
UK Brexit
Health Care Private Equity Investments in India -
A flurry of recent private equity (PE) investments in the Indian health care sector demonstrates strong investor appetite and opportunities.
India is one of the fastest...more
The Internal Revenue Service (IRS) has issued PMTA 2018-016, reaffirming its position that for taxpayers making an election under Internal Revenue Code (Code) Section 965(h) to pay the transition tax over eight years through...more
We previously discussed the Internal Revenue Service’s (IRS) surprising position that for taxpayers making an election under Internal Revenue Code (Code) Section 965(h) to pay the transition tax over 8 years through...more
In a surprising development, the Internal Revenue Service (IRS) has announced that if a taxpayer’s 2017 payments, including estimated tax payments, exceed its 2017 net income tax liability described under Internal Revenue...more
The recent US tax reform act carries potential ramifications for bilateral investment between the United States and China. We take a closer look at how tax reform might affect US multinationals operating in China, Chinese...more
The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new inclusion rule for non-routine CFC income, termed “global intangible low-taxed income” (GILTI). The...more
On December 22, 2017, President Trump signed broad tax reform legislation into law that, among other things, reduced the corporate income tax rate to 21 percent and reformed the US international tax system. This article...more
A House-Senate conference committee has reached agreement on a compromise version of the Tax Cuts and Jobs Act, which includes substantial changes to the corporate and international business taxation rules. The stage now...more
The Senate has passed its version of the Tax Cuts and Jobs Act, which includes substantial changes to the corporate and international business taxation rules. Senate passage was probably the most significant political and...more
The Senate Finance Committee Chairman’s Mark of the Tax Cuts and Jobs Act includes substantial proposed changes to the corporate and international business taxation rules. While this proposal will evolve further in committee...more
The newly introduced Tax Cuts and Jobs Act is a comprehensive tax reform package that touches virtually every area of the tax law. Though largely consistent with September’s tax reform Framework, new details reveal the...more
Substantial tax reform is underway and the business community is intently awaiting details of this activity with the aim of positioning themselves to maximize opportunities and minimize any costs or risks that reform may...more
9/22/2017
/ Business Taxes ,
Corporate Taxes ,
Executive Orders ,
Income Taxes ,
International Tax Issues ,
IRS ,
Multinationals ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
Undue Burden
In a long-awaited decision, the Tax Court recently held that gain realized by a foreign taxpayer on the sale of a partnership engaged in a US trade or business was a sale of a capital asset not subject to US tax, declining to...more
Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations -
Introduction:
On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more
10/5/2015
/ Administrative Procedure Act ,
Amended Regulation ,
BEPS ,
Clawbacks ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Cost-Sharing ,
Foreign Corporations ,
Goodwill ,
Intangible Property ,
IRC Section 367 ,
IRS ,
Partnerships ,
Proposed Regulation ,
Section 482 ,
Stock-Based Compensation ,
Tax Court ,
Tax Reform ,
Transfer Pricing ,
Transfers ,
U.S. Treasury