The book has closed on 2023, but several recent tax-related rulings are sure to have ripple effects into 2024 and beyond—particularly with respect to transfer pricing and foreign tax credits. Here are five cases that will...more
1/9/2024
/ Chevron Deference ,
Economic Substance Doctrine ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Moore v US ,
Oral Argument ,
SCOTUS ,
Tax Court ,
Tax Credits ,
Taxation ,
U.S. Treasury
Introduction On August 16, President Biden signed into law the Inflation Reduction Act of 2022, P.L. 117-169 (IRA). The law addresses a range of issues, from climate change to energy security to prescription drug prices for...more
In 2019, we published analysis to help tech and life sciences companies navigate U.S. tax law changes, an evolving IP landscape and new privacy regulations such as the California Consumer Privacy Act. We also tracked venture...more
1/8/2020
/ ABC Test ,
California Consumer Privacy Act (CCPA) ,
Consumer Privacy Rights ,
Convertible Debt ,
Corporate Governance ,
Data Privacy ,
Debt Financing ,
Direct Listing ,
Diversity ,
Emerging Technology Companies ,
Employer Liability Issues ,
Foreign Tax Credits ,
Hiring & Firing ,
Independent Contractors ,
Intellectual Property Litigation ,
Intellectual Property Protection ,
Internal Revenue Code (IRC) ,
IRS ,
Life Sciences ,
Misclassification ,
New Guidance ,
Pharmaceutical Industry ,
Privacy Laws ,
Proposed Regulation ,
Proxy Season ,
Silicon Valley ,
Startups ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Venture Capital ,
Withholding Tax ,
Woman Board Members
On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more
1/6/2020
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Final Rules ,
Foreign Earned Income ,
Foreign Tax Credits ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
Proposed Regulation ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Planning ,
U.S. Treasury
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
12/13/2018
/ Allocation of Funds ,
Banking Sector ,
Books & Records ,
CFC ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Taxes ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Foreign Banks ,
Foreign Corporations ,
Foreign Tax ,
GILTI tax ,
Income Taxes ,
Interest Payments ,
IRS ,
Multinationals ,
New Rules ,
Parent Corporation ,
Partnerships ,
Proposed Regulation ,
Royalties ,
Stocks ,
Subpart F ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Exemptions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Tax Returns ,
Taxable Distributions ,
U.S. Treasury