PLR 202304008: Taxpayer Does Not Have Section 961(b)(2) Gain for Mid-Year Distributions -
Introduction to Section 961 and Mid-Year Distributions -
For years, there has been a longstanding question under the subpart F...more
The IRS has for the second time in as many years included monetized installment sales on its annual “Dirty Dozen” tax schemes list. As we discussed in a prior post, the “Dirty Dozen” list alerts taxpayers and practitioners to...more
Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure -
U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more
1/25/2023
/ Business Entities ,
Corporate Structures ,
Corporate Taxes ,
FBAR ,
Foreign Corporations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Parent Corporation ,
Tax Liability ,
Tax Planning ,
Tax Treaty
IRS Chief Counsel Memoranda: Cryptocurrency Donations Above $5,000 Need Qualified Appraisal and No Unrealized Cryptocurrency Loss Without Disposition -
Introduction -
The IRS recently released two chief counsel...more
Introduction: Consolidated Groups and Section 951(a)(2)(B) Tax Planning -
On December 9, 2022, Treasury and the IRS released proposed regulations that are intended to stop certain U.S. shareholder tax planning under...more
Eleventh Circuit Sides with Ninth Circuit on Section 6751(b) Circuit Split -
Introduction: Section 6751(b) and the Timing of Supervisory Approval of a Penalty -
The Eleventh Circuit’s decision in Kroner v. Commissioner,...more
12/14/2022
/ Enforcement Actions ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Reporting Requirements ,
Tax Court ,
Tax Evasion ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Returns
GRAs and Section 367(a)(1) Outbound Stock Transfer Rules Overview - Introduction to Section 367(a)(1), Outbound Stock Transfers, and Gain Recognition Agreements - Section 367(a) of the Internal Revenue Code (the “Code”)...more
Section 245A: Tax Efficient Repatriation of a Foreign Subsidiary’s Earnings -
Freeman Law frequently advises U.S. multinational corporations. United States-based international businesses are subject to complex reporting...more
10/21/2022
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
GILTI tax ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
Passive Foreign Investment Company ,
Subpart F ,
Tax Cuts and Jobs Act ,
Tax Reform
On September 21, 2022, the U.S. District Court for the Southern District of New York granted the IRS’s ex-parte motion for leave to serve a John Doe summons to M.Y. Safra Bank after the IRS’s investigation into digital asset...more
This year the extended tax filing deadline for U.S. citizens or residents, sole proprietorships, C corporations, and single-owner LLCs is Monday, October 17, 2022. Through the course of the tax year companies often engage in...more