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Five Key Takeaways From the Proposed PTEP Regulations

Taxpayers have been eagerly awaiting, and the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have been promising to provide, rules addressing the previously taxed earnings and profits (PTEP)...more

[Event] - 2019 Tax Symposium - May 8th, Chicago, IL

Join us for a forward-looking full-day program with discussions led by our senior tax practitioners. The team will examine the current tax landscape, discuss the impact on decisions at the world’s largest corporations and...more

Proposed Regulations under Section 956 Provide Benefits for Corporate Taxpayers

On October 31, 2018, the Internal Revenue Service (IRS) and US Department of the Treasury (Treasury) released proposed regulations (REG-114540-18) (the Proposed Regulations) that would prevent, in many cases, income...more

US Tax Costs Significantly Reduced on Sale of CFC Stock

Following the 2017 Tax Act, the US tax costs to a corporate US shareholder that sells stock in a controlled foreign corporation (CFC) are significantly reduced. Beginning in 2018, the amount of gain will be generally less...more

Tax Reform Conference Committee Reaches Agreement

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

M&A Tax Aspects of Republican Tax Reform Framework

The outline of pending tax reform provisions remain vague, but a significant impact on M&A activity is expected by way of corporate tax cuts, interest deductibility, changes to the expensing of capital investments, a...more

New IRS Rulings Should Provide Greater Certainty for Corporate Restructurings

On May 5, 2015, the Internal Revenue Service (IRS) issued two long-awaited rulings, Rev. Rul. 2015-09 and Rev. Rul. 2015-10, that should ease the lives of corporate tax planners. Each ruling addressed an increasingly common...more

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