After a cross-border merger or acquisition, related affiliates often integrate and use the acquired intangibles, such as new ...
Focusing on private-equity acquisitions, this article compares merger forms and highlights tax considerations, particularly ...
Practitioners must observe and protect time limits for requesting a refund, administrative appeals, and litigation.
Acquaintance with relevant Internal Revenue Manual provisions can aid practitioners in protecting clients’ rights in tax ...
Hyatt appealed the Tax Court’s decision to the Seventh Circuit. On appeal, Hyatt renewed its arguments that the payments into ...
Tax Court disallows part of a taxpayer’s Sec. 245A dividends-received deduction and holds post–Sec. 965(c) amount must be ...
Taxpayers issuing related-party loans should assess the consequences if those debt instruments are determined to have a zero ...
Foreign companies can realize benefits from establishing domicile in the United States if they observe structural and special ...
Recent changes to the rules related to the deduction for certain foreign dividends received by U.S. corporate shareholders could substantially reduce the abuse concerns that the extraordinary ...
To follow ethical behavior in the accounting profession, CPAs must observe the AICPA Code of Professional Conduct (the AICPA Code). CPAs who perform tax services must also follow the AICPA Statements ...
Undocumented immigrants venture to the United States from all parts of the world and endure enormous challenges in their new life, ranging from cultural ones to those that are language–oriented in ...
Amid new limitations, strategies remain for optimizing tax-efficient support for colleges and universities.
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