Code Sec. 367(a) and (d) After the TCJA

January 3, 2020

International Tax Journal: Code Sec. 956 Proposed Regs

March 8, 2019

Proposed Regulations under Section 956 Provide Benefits for Corporate Taxpayers

November 20, 2018

Bloomberg Tax: Prop. GILTI Regs: ‘Tested Income’

November 15, 2018

Tax Reform Insight: US Tax Costs Significantly Reduced on Sale of CFC Stock

September 13, 2018

Tax Reform Insight: IRS Slams Door on Refunds/Credits for Taxpayers with Section 965 Transition Tax Liability

August 21, 2018

Tax Reform Insight: Eligibility Requirements for Reduced Tax Rate on FDII for Royalties

July 18, 2018

Tax Reform Insight: New Foreign Tax Credit Rules May Warrant Restructuring Foreign Branches

June 27, 2018

Tax Reform Insight: IRS Doubles Down on Retention of 2017 Overpayments to Satisfy Future Section 965 Installment Payments

June 19, 2018

IRS Holding 2017 Overpayments to Satisfy Future Section 965 Liabilities

May 9, 2018