Under immense pressure to devise a fair and administrable solution for taxing digital businesses by 2020, the OECD yesterday released a public consultation document to test the waters with a potent
The U.S. Department of Justice (DOJ) continues to focus on cross-border investigations, leading to indictments of not only U.S. businessmen but also executives living abroad.
On October 11, 2019, the U.S. International Trade Commission (ITC) will begin accepting petitions for duty suspensions or reductions under the Miscellaneous Tariff Bill (MTB). Under the MTB, U.S.
On April 4, 2016, proposed regulations ("Proposed Regulations") under Internal Revenue Code section 3851 were issued that generally recharacterize related party debt as equity in whole o
On Thursday, November 19, 2015, the U.S.
The Bipartisan Budget Act of 2015 (the Act)1 that was signed into law on November 2, 2015, dramatically changes the rules for Internal Revenue Service (IRS) audits of partnerships and in
In this article, Patricia Sweeney, Alan Horowitz and Andrew Howlett discuss the Tax Court's decision in Altera Co
In Altera Corp. v. Commissioner, 145 T.C. No. 3 (July 27, 2015), the Tax Court put the Internal Revenue Service (IRS) and U.S.
In this article, Andrew Howlett and Lisandra Ortiz analyze Chemtech Royalty Associates LP v.
On April 10, 2015, the Internal Revenue Service (the Service) issued Chief Counsel Advice (CAA) 201515020, which applied the economic substance doctrine to disregard the taxpayers' participation in
In this article, Andrew Howlett discusses the pitfalls of the Washi
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