Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more
3/11/2025
/ Compliance ,
Corporate Taxes ,
Final Rules ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Regulatory Requirements ,
Tax Liability ,
Tax Planning ,
U.S. Treasury
Taxpayers have been eagerly awaiting, and the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have been promising to provide, rules addressing the previously taxed earnings and profits (PTEP)...more
Mark your calendars to join us for our year-in-review program that will cover key tax and employee benefits issues affecting the state and local, federal and international legal landscape. We will conclude our program with...more
12/2/2022
/ Compensation & Benefits ,
Employee Benefits ,
Events ,
Federal Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Local Taxes ,
State Taxes ,
Tax Liability ,
Tax Planning
On September 23, 2022, the Internal Revenue Service (IRS) released a memorandum (AM 2022-003) concluding that taxpayers cannot make advance payments of section 367(d) inclusions except in the limited situation in which the US...more
On August 10, 2022, a petition for writ of certiorari filed by Whirlpool Financial Corporation & Consolidated Subsidiaries and Whirlpool International Holdings S.a.r.l. & Consolidated Subsidiaries (collectively, Whirlpool)...more