Author Archives: Stefanie Kavanagh

Stefanie Kavanagh
Stefanie Kavanagh is an associate in the Federal & International Tax Group. She focuses her practice on tax planning and structuring for domestic and international business entities as well as matters relating to real estate investment trusts.  Read More

International Tax ADVISORY: Big Tax Court Win for Eaton in Canceled APA Case

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The IRS abused its discretion when it canceled two advance pricing agreements. Our International Tax Group covers Eaton’s victory in the Tax Court and how it allays concerns about how worthwhile an APA can be. Public and judicial scrutiny Standard of review Where do we go from here? Read the full advisory here. [...]Read more

Federal & International Tax ADVISORY: Big Tax Court Win for Foreign Investors in U.S. Partnerships

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Our Federal & International Tax Group examines the long-awaited decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner. While a win for foreign investors in U.S. partnerships, it may not be the final word. Repudiates decades-long position of IRS May have a real impact on U.S. foreign investment May not be the last word on the subject Read the full advisory here. [...]Read more

International Tax ADVISORY: Impact of the Multilateral Instrument of U.S. Taxpayers

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Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all means for U.S. companies. What is the multilateral instrument? Why didn’t the U.S. sign it? How will it impact U.S. multinationals? Read the complete advisory here. [...]Read more

International Tax ADVISORY: Tax Court Déjà Vu – IRS Tried, and Failed, to Overturn Veritas

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Unsurprisingly, the IRS got the same result by trying the same thing. Our International Tax Group analyzes the agency's latest effort to use a discounted cash flow analysis to audit a cost-sharing agreement. The difference between #255 million and $3.6 billion Using the comparable uncontrolled transaction method Applying the 2011 cost-sharing regulations Read the full advisory by clicking here. [...]Read more

Killing the Killer B: The Treasury and IRS Issue a Sixth Set of Rules on Killer B Transactions

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The Treasury looks to slay Killer B transactions with its newest rules. Our International Tax Group follows the trail of glitches in the regulation.

Read the full advisory here.

Qualification of Certain Section 355 Spinoff Transactions Added to No-Rule List as IRS and Treasury Study the Topic

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On September 14, 2015, the government released Notice 2015-59 and Rev. Proc. 2015-43, both relating to Section 355 spinoffs. They respond to government concerns about spinoff transactions that result in the distributing corporation or the controlled corporation owning a substantial amount of cash, portfolio stock or securities, or other investment assets, in relation to the value of all of its assets and its qualifying business assets. In the Notice, the government states that it has become aware, in part through private letter ruling requests, that these transactions may present evidence of device [...]Read more