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Brian Harvel

Brian Harvel

About Brian Harvel

Brian Harvel is a partner in the Federal & International Tax Group whose practice focuses on complex tax structuring and planning for a wide range of domestic and international business entities.

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Digital Services Taxes and Nexus for Foreign Tax Credit Purposes

February 17, 2021 By Brian Harvel and April McLeod

Our International Tax Group reviews Treasury’s proposed regulations that would add a jurisdictional nexus requirement to the analysis used to determine whether a foreign tax is an income tax for foreign tax credit purposes. What is the new jurisdictional nexus requirement?Why is Treasury worried about Europe’s digital services taxes?What are the arguments against the new nexus requirement? Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: foreign tax credit, FTC, Income Tax, IRS, nexus, OECFD, Organisation for Economic Co-operation and Development, Treasury

State of Uncertainty: GILTI Considerations for Individuals

October 15, 2018 By Daniel Reach and Brian Harvel

Our International Tax Group explores the hidden terrain for individuals found in the new tax on global intangible low-taxed income (GILTI).

The Section 250 deduction
The renewed importance of Section 962
Beware of the C-corp. lobster pot

Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: CFC, Controlled Foreign Corporations, Domestic C, GILTI, Subpart F, Tax Cuts and Jobs Act, tax reform, TCJA

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Recent Posts

  • If at First You Don’t Succeed, Try, Try Again to Enact the Nation’s First Digital Advertising Services Tax
  • Digital Services Taxes and Nexus for Foreign Tax Credit Purposes
  • FAQs on Unclaimed Property Aspects of Retirement Assets
  • UP Front: A 2021 Sightline for Unclaimed Property Professionals
  • 45Q Regulations Will Spur Carbon Capture and Storage Investment

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