What does a (barely) Democratic Senate mean for Biden’s tax plans? Our International Tax Group discusses the President-elect’s broad proposals and how they could change the cross-border tax landscape. Raising the corporate and capital gain tax … [Continue reading] about Biden’s International Tax Proposals – No Longer a Long Shot After Democrats Win in Georgia
How to Price in a Pandemic: New OECD Guidance on Transfer Pricing Challenges Caused by COVID-19
Our International Tax Group examines how the Organisation for Economic Co-operation and Development’s new guidance reiterates the central role of the arm’s-length standard and provides guideposts for taxpayers and tax administrations as they analyze … [Continue reading] about How to Price in a Pandemic: New OECD Guidance on Transfer Pricing Challenges Caused by COVID-19
IRS Issues CARES Act Guidance Addressing Tax Issues Prevalent in M&A Transactions
The CARES Act’s Paycheck Protection Program (PPP) was a boon to many businesses, but some of its particularities have become a headache to acquiring taxpayers. Our Federal Tax Group untangles how PPP loans affect employee retention credits and … [Continue reading] about IRS Issues CARES Act Guidance Addressing Tax Issues Prevalent in M&A Transactions
Letter Ruling Conjures Ghost of Section 958(b)(4) Past
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 … [Continue reading] about Letter Ruling Conjures Ghost of Section 958(b)(4) Past
Sourcing the Source of Inventory Sales – Final Regulations Under Section 863(b)
Is inventory personal? Well, it depends. In case you missed it, our International Tax Group recently explored the finalized sourcing rules that decide whether inventory is U.S. or foreign source after changes wrought by the Tax Cuts and Jobs … [Continue reading] about Sourcing the Source of Inventory Sales – Final Regulations Under Section 863(b)