Category Archives: Federal Tax Advisory

Foreign-Derived Intangible Income

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It’s probably the next-best part of the Tax Cuts and Jobs Act for multinationals. Our Federal Tax Group investigates the foreign-derived intangible income regime and how you can use it. What is an export? Getting the CFC involved Selling a service Read the full advisory here. [...]Read more

Tax Act: Vote and Value

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Our Federal Tax Group explains the nuances tax reform brings to the definition of a U.S. shareholder, including a surprise for controlled foreign corporations.

  • U.S. shareholders
  • The vote or value definition
  • Controlled foreign corporations

Click here to read the full advisory.

Tax Change Planning

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With tax cuts likely coming, it might make sense to consider establishing a C corporation for some new businesses. Our Federal Tax Group offers tax planners several different ways of thinking. Tax Reform Act of 1986 Payment of dividends and stock buybacks Less advantageous structures Read the full advisory here. [...]Read more

Federal Tax ADVISORY: Dual-Class Stock Blessing for Spin

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A new Letter Ruling from the IRS brings concerns for corporations looking at a spinoff. Our Federal Tax Group breaks down the guidelines and what they mean.

  • Dual-class structure
  • Debt
  • Delayed transfers

Read the full advisory here.

Federal Tax ADVISORY: Partial Worthlessness

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Don’t overlook claiming a deduction for partial worthlessness. Our Federal Tax Group provides a refresher on this useful tool.

  • Cross-border or brother-sister debt
  • A hard pill to swallow
  • Ordinary loss

Read the full advisory here.

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