5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
The Demystification of Employee Retention Credits for Private Equity Deals — PE Pathways Podcast
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
What is Reverse Vesting and What are the Tax Considerations?
What's the Best Transaction Structure for My Sale?
Death, Taxes and Politics: The Future of Tax Policy Ahead of the 2024 Election
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
How Tax Works - Entity Selection
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Update on Pillar Two: Where it Stands Today and What To Expect
GILTI Conscience Podcast | Spotlight Series: Carving Your Path in Transfer Pricing
On May 22, 2025, the U.S. House of Representatives approved H.R. 1, also known as the “One Big Beautiful Bill Act” (the House Bill). The House Bill will next be considered by the U.S. Senate, and the administration has set a...more
The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more
2018 was a very active year for tax developments. The big story was the application of the substantial reforms of the Tax Cuts and Jobs Act of 2017, which took initial effect in 2018. But there were several other developments...more
Introduction and Overview - The Tax Cuts and Jobs Act (“TCJA”) resulted in the most sweeping changes to the Internal Revenue Code (the “Code”) in decades and will result in countless articles and commentary to address the...more
On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more
Perhaps some of the most extensive changes in H.R. 1, known as the Tax Cuts and Jobs Act (the “Act”), deal with the taxation of multinational companies. The taxation of foreign earnings has long been a point of contention...more
The Situation: The Trump Administration, in collaboration with the House and Senate, has introduced a Framework for tax reform legislation that could bring sweeping changes to U.S. tax laws....more
On September 27, 2017, the Trump Administration, the House Committee on Ways and Means and the Senate Committee on Finance released their much-anticipated framework for tax reform (the “Framework”). The Framework generally...more
On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more
On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more
NUMBER OF THE WEEK: 10 percent. Rate of the one-time deemed repatriation tax on U.S. multinationals’ foreign earnings under GOP presidential candidate Donald Trump’s tax plan released Sept. 28. The revenue raised through...more