09.16.2020
On September 1, 2020, Treasury and the IRS released additional guidance under section 59A, the base erosion and anti-abuse tax (BEAT) added by the 2017 Tax Cuts and Jobs Act.1 These fina
Tax Alert
07.20.2020
On July 9, 2020, Treasury and the IRS released final regulations under section 250, which provides a deduction for a domestic corporation's foreign derived intangible income (FDII) and global intan
Tax Alert
03.21.2020
What was shaping up to be another year of tax gridlock in Washington has, like seemingly everything else, been disrupted by the coronavirus outbreak.
10.10.2019
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
Tax Alert
06.24.2019
On June 14, 2019, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) simultaneously issued proposed regulations (GILTI Proposed Regulations)1 and final regulati
Tax Alert
04.30.2019
Almost 18 months after the passage of the Tax Cuts and Jobs Act of 2017 (TCJA), tax executives remain undecided about the law's impact on U.S.
03.07.2019
On March 4, 2019, Treasury and the IRS issued proposed regulations (Proposed Regulations) under section 250.1 The 2017 Tax Cuts and Jobs Act added section 250, which provides a deduction
Tax Alert
12.20.2018
On December 13, 2018, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 59A, the base erosion and anti-ab
Tax Alert
11.29.2018
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
Tax Alert
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