The Senate Finance Committee's version of the Republicans' budget reconciliation legislation (the “Senate Bill”) would significantly expand the qualified small business stock (QSBS) benefits under Section 1202 of the Code...more
On May 22, 2025, the U.S. House of Representatives passed a reconciliation bill (commonly referred to as the “One Big Beautiful Bill”), which would restore expensing for domestic research and development expenses incurred in...more
6/6/2025
/ Biotechnology ,
Budget Reconciliation ,
Corporate Taxes ,
Federal Budget ,
Income Taxes ,
Life Sciences ,
Proposed Legislation ,
Research and Development ,
Tax Credits ,
Tax Deductions ,
Tax Incentives ,
Tax Reform
One of the more significant issues that taxpayers and tax practitioners have faced in recent months is the Tax Cuts and Jobs Act’s (TCJA) amendment to Section 174, requiring capitalization of previously deductible R&D and...more
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
12/13/2018
/ Allocation of Funds ,
Banking Sector ,
Books & Records ,
CFC ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Taxes ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Foreign Banks ,
Foreign Corporations ,
Foreign Tax ,
GILTI tax ,
Income Taxes ,
Interest Payments ,
IRS ,
Multinationals ,
New Rules ,
Parent Corporation ,
Partnerships ,
Proposed Regulation ,
Royalties ,
Stocks ,
Subpart F ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Exemptions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Tax Returns ,
Taxable Distributions ,
U.S. Treasury
The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more
9/18/2018
/ Asset Management ,
C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Taxes ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
New Rules ,
Partnerships ,
Pass-Through Entities ,
Private Equity Firms ,
Shareholders ,
Stock Purchase Agreement ,
Stock Sale Agreements ,
Stocks ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning ,
Tax Reform
A new IRS legal advice memorandum addresses a fact pattern that may become more common in the wake of Tax Reform—sale of intangible property from a controlled foreign corporation to its United States parent—and highlights the...more
6/25/2018
/ Amortization ,
Churning ,
Controlled Foreign Corporations ,
Corporate Branding ,
Foreign Subsidiaries ,
Franchises ,
Intangible Property ,
IP License ,
IRS ,
Multinationals ,
Parent Corporation ,
Tax Reform
Recent months have seen significant IRS and judicial developments affecting financial institutions and market participants, including new FATCA changes and proposed regulations on dividend equivalent payments under section...more