On November 26, 2018, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 163(j).1 The 2017 Tax
Last week's Ninth Circuit decision in
Just months after passage of the first comprehensive tax reform law enacted in more than 30 years, tax executives are optimistic about the effect of the Tax Cuts & Jobs Act (TCJA) on their busi
The Internal Revenue Service (IRS) Large Business & International Division (LB&I) is transitioning to a centralized compliance and examination process that focuses on issue-based campaigns.
Miller & Chevalier Chartered and the National Foreign Trade Council (NFTC) today announced the results of their 2017 Tax Policy Forecast Survey, which reveals for the first time in 11 years sig
Over the past decade, the 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
In this article, Layla Asali and Rocco Femia discuss Section 367(a) and §3
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