After a cross-border merger or acquisition, related affiliates often integrate and use the acquired intangibles, such as new ...
Acquaintance with relevant Internal Revenue Manual provisions can aid practitioners in protecting clients’ rights in tax ...
Thresholds and ceilings for individual and corporate deductions under the law known as the One Big Beautiful Bill Act may ...
Taxpayers issuing related-party loans should assess the consequences if those debt instruments are determined to have a zero ...
Focusing on private-equity acquisitions, this article compares merger forms and highlights tax considerations, particularly ...
Even though recent changes substantially reduced abuse concerns, U.S. corporate shareholders must still comply with the extraordinary reduction rules when deducting certain foreign dividends.
Tax Court disallows part of a taxpayer’s Sec. 245A dividends-received deduction and holds post–Sec. 965(c) amount must be ...
Hyatt appealed the Tax Court’s decision to the Seventh Circuit. On appeal, Hyatt renewed its arguments that the payments into ...
Practitioners must observe and protect time limits for requesting a refund, administrative appeals, and litigation.
Foreign companies can realize benefits from establishing domicile in the United States if they observe structural and special ...
Amid new limitations, strategies remain for optimizing tax-efficient support for colleges and universities.
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