Our International Tax Group elaborates on the final regulations recently issued by the IRS and Treasury on the base erosion and anti-abuse tax (BEAT). Key changes from the regulations proposed in 2019Clarification on determining a taxpayer’s … [Continue reading] about The BEAT Goes On and On – New Final BEAT Regulations
Treasury’s High Wire Act – Final and Proposed Regulations on CFC High-Tax Exceptions
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 … [Continue reading] about Treasury’s High Wire Act – Final and Proposed Regulations on CFC High-Tax Exceptions
Challenges With Escheatment of Tax-Deferred Retirement Assets, Part 2
Holders of tax-deferred retirement assets must weigh and balance significant owner-facing risks against a clear set of state-facing compliance requirements and risks. In this installment of “UP Ahead” for Tax Notes State, unclaimed property partners … [Continue reading] about Challenges With Escheatment of Tax-Deferred Retirement Assets, Part 2
Don’t Forget Ruling Guidelines
Take a trip down memory lane as our Federal Tax Group leads you through past IRS ruling guidelines still in effect. Rev. Proc. 2020-1 is a good reference for effective ruling guidelinesEven old ruling guidelines can apply to a “significant … [Continue reading] about Don’t Forget Ruling Guidelines
Pushing Beyond the Limit: Examining the Scope of Subpoenas Issued During Unclaimed Property Audits
A Delaware court quashed a subpoena aimed at an unclaimed property holder, but the victory may be short-lived. Our Unclaimed Property Team explores the latest court decision addressing a subpoena for records dating back to the 1990s. The subpoena … [Continue reading] about Pushing Beyond the Limit: Examining the Scope of Subpoenas Issued During Unclaimed Property Audits