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
Our International Tax Group explores a recent, heavily redacted Chief Counsel Advice applying the partnership abuse of entity rule to a Section 367(d) outbound IP transaction. Outbound IP transfers and Section 367(d) The partnership abuse of entity rule Interaction between the partnership abuse of entity rule and Section 367(d) successor rules Read the full advisory here. [...]Read more
With tax reform officially upon us, our subject matter experts will take a deeper dive into areas that are critical to your business, such as corporate taxes, international issues, executive compensation and employee benefits, and partnerships. The 2018 call-in series will kick off on Tuesday, January 9. All seminars will start at 11am ET and last approximately 30 minutes. Click here to RSVP and receive the dial-in information. [...]Read more
Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all means for U.S. companies. What is the multilateral instrument? Why didn’t the U.S. sign it? How will it impact U.S. multinationals? Read the complete advisory here. [...]Read more
The Treasury looks to slay Killer B transactions with its newest rules. Our International Tax Group follows the trail of glitches in the regulation.