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Edward Tanenbaum

About Edward Tanenbaum

Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.

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What’s in a Name? Final FTC Regulations Rebrand the Jurisdictional Nexus Requirement

January 18, 2022 By Edward Tanenbaum and Stefanie Kavanagh

Our International Tax Group delves into the attribution requirement (née jurisdictional nexus requirement) of the final foreign tax credit regulations and finds that taxpayers will still face uncertainties in the application of the foreign tax credit. The IRS seeks to modernize regulations to mitigate double taxation of foreign-source income Many of the final regulations follow the proposed regulations, but some were modified based on comments from taxpayers Gray areas remain, including how reasonably similar a foreign rule must be Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: attribution requirement, FTC, international tax, jurisdictional nexus requirement, OECD, Pillar One, regulations, Tax

The Other Green Book: Treasury Explains Administration’s Tax Proposals

June 16, 2021 By Edward Tanenbaum, Heather Ripley and April McLeod

With the release of its FY 2022 revenue proposals, the Biden Administration explains and refines some of the tax priorities raised on the campaign trail. Our International Tax Group reads the tea leaves to find the significant changes to the Tax Code the Administration won’t find easy to navigate through a Congress that features the slimmest of majorities. Major revisions to the Tax Cuts and Jobs Act of 2017Tighter rein on interest deductions and inversionsRepealing BEAT and FDII, creating a new SHIELD against base erosion Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: base erosion, BEAT, Biden Administration, CFC, crypto, FDII, global minimum tax rate, Green Book, SHIELD, tax reform, Treasury

Letter Ruling Conjures Ghost of Section 958(b)(4) Past

November 23, 2020 By Edward Tanenbaum and Heather Ripley

The Tax Cuts and Jobs Act of 2017 continues to reverberate even unto the end of 2020. Our International Tax Group discusses a letter ruling that may have been a harbinger of proposed regulations to address exceptions to Section 367(a) gain recognition in light of the TCJA’s repeal of Section 958(b)(4). The specter of foreign-to-U.S. downward attributionCurtailing collateral effects of the repeal of Section 958(b)(4)Proposed regulations formalize pre-TCJA approach in targeted Section 367(a) context Click here to read the full advisory. [...]Read more

Filed Under: International Tax Advisory Tagged With: IRS, Letter Ruling, Section 367(a), Section 958(b)(4), Tax Cuts and Jobs Act, tax reform, TCJA

Treasury’s High Wire Act – Final and Proposed Regulations on CFC High-Tax Exceptions

August 18, 2020 By Edward Tanenbaum and Heather Ripley

Our International Tax Group examines the high-tax exclusion (HTE) in new final regulations under the global intangible low-taxed income (GILTI) regime and the potentially precarious side effects U.S. shareholders face in choosing whether to apply the HTE. The 2020 final regulations apply the GILTI HTE on a “tested unit” and “all or nothing” basisThe 2020 proposed regulations would conform the Subpart F HTE to the finalized GILTI HTE, creating a single unified HTE for both regimesThe decision whether to elect the GILTI HTE must balance implications under other TCJA provisions and possibly [...]Read more

Filed Under: International Tax Advisory Tagged With: CARES Act, CFC, GILTI, high-tax exclusion, HTE, QBU, Section 267, Section 951, Section 954, Subpart F, tax reform, TCJA

Final FDII Regulations Released

July 16, 2020 By Edward Tanenbaum, Richard Slowinski and Stefanie Kavanagh

Talk about a summer beach read... The IRS’s final regulations for Section 250 deductions for FDII and GILTI are here for your light summer reading. Better yet, let our International Tax Group explain it all for you. The Section 250 deduction generally applies to domestic C corporationsA more relaxed and flexible approach to documentation and substantiation requirementsClarification for the software industry on foreign use of digital sales and advertising Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: advertising, CFC, Controlled Foreign Corporations, digital sales, FDII, GILTI, IRS, REITs, RICs, Section 250

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