What does a (barely) Democratic Senate mean for Biden’s tax plans? Our International Tax Group discusses the President-elect’s broad proposals and how they could change the cross-border tax landscape....more
Our International Tax Group addresses an election under Section 962 available to individual U.S. shareholders of certain foreign corporations to be taxed as a C corporation, which before tax reform was a rarely utilized and...more
The Tax Cuts and Jobs Act, signed into law on December 22, 2017, represents the biggest change to U.S. tax law since adoption of the 1986 Code. In addition to rate cuts and various individual and corporate reforms, the Act...more
Tax reform is coming, and Republican leaders have published a framework that raises as many questions as it answers. Our Tax Policy & Regulation Team investigates what the Big Six reveal and—just as important—what they don’t....more
LTR 201542004 at first seems to involve a standard spinoff for the purpose of pursuing a reverse Morris Trust combination of Controlled with a Merger Partner, with the “significant issue” for ruling being a proposed swap of...more