At long last, we have the first set of final regulations for the Tax Cuts and Jobs Act. Our International Tax Group celebrates with a look at how the Treasury and IRS have clarified Section 965 and why taxpayers may need to...more
In long-awaited guidance on Section 163(j) post-tax reform, the Treasury and IRS present taxpayers with an expansive definition of “interest,” subjective anti-abuse rules, complex computational instructions, and several...more
With tax reform on the horizon, Treasury takes aim at three sets of regulations with clear cross-border implications. Our International Tax Group explains the department’s recommendations to scrap much of Section 385 and...more
With tax cuts likely coming, it might make sense to consider establishing a C corporation for some new businesses. Our Federal Tax Group offers tax planners several different ways of thinking....more