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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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Get Out Your Crystal Ball: The Challenges of Tax Planning in the Current Age of Uncertainty

August 13, 2021 By Seth Buchwald and Brian Harvel

It is said the future is not yet written. But the Biden Administration has a draft ready for Congress. Our Federal Tax Group gazes into the Made in America tax plan to find the many questions that await within. The uncertainty of retroactive or prospective effective datesDeferring income recognition and accelerating deductions may not be the best planPrepare to reexamine traditional tax planning strategies Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: American Jobs Plan, Infrastructure

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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