News & Analysis as of

Internal Revenue Service Tax Avoidance Corporate Taxes

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
McDermott Will & Emery

FedEx Defeats Government’s Loper Bright Gambit

McDermott Will & Emery on

On February 13, 2025, a Tennessee federal district court handed FedEx Corporation its second win in a refund action involving the application of foreign tax credits to what are known as “offset earnings.”[1] Offset earnings...more

Holland & Knight LLP

Tax Court: As to Listed Transaction, IRS Must Adhere to APA

Holland & Knight LLP on

In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more

Eversheds Sutherland (US) LLP

No rest for the weary - final regulations continue to target inversions without major changes

INTRODUCTION - On July 11, 2018, Treasury and the Internal Revenue Service (IRS) published final inversion regulations (TD 9834) which are largely consistent with the temporary (T.D. 9761) and proposed regulations...more

Wilson Sonsini Goodrich & Rosati

IRS Releases Final Regulations Addressing Corporate Inversions and Related Transactions

On July 11, 2018, the U.S. Treasury Department and the Internal Revenue Service (the IRS) issued final regulations under Section 7874 and related sections of the Internal Revenue Code of 1986, as amended, (the Code)...more

Farrell Fritz, P.C.

When Investing In A Partnership May Be A Tax Problem

Farrell Fritz, P.C. on

A business entity that is treated as a “flow-through” for income tax purposes enjoys the benefit of a single level of tax – the entity itself is typically not subject to tax on its net income; rather, that income “flows...more

King & Spalding

New Guidance Rewrites Debt/Equity Rules and Further Limits Inversions

King & Spalding on

The IRS and Treasury Department released a package of temporary and proposed regulations on April 4, 2016 ostensibly aimed at further curbing corporate “inversion” transactions. The regulations cover a wide range of tax...more

Proskauer - Tax Talks

IRS Proposes Country-by-Country Reporting Regulations

Proskauer - Tax Talks on

On December 21st, 2015 the IRS proposed Country-by-Country (“CbC”) reporting rules requiring certain U.S. multinational companies to provide extensive information about business operations (including their revenue, number of...more

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