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06.13.2025

Firm Publication

Tax Court Issues Split Ruling in Facebook

Tax Alert

05.14.2025

Firm Publication

Applying Transfer Pricing Principles to Determine Customs Value on Which Tariffs Are Imposed

Tax Alert

05.13.2025

Firm Publication

Collateral Issues Dominate in Final Briefing for Varian and Sysco

Tax Alert

04.10.2025

Firm Publication

Using the First Sale Rule to Reduce Tariffs

International and Tax Alert

04.03.2025

Firm Publication

Tariff Increases Create Transfer Pricing Challenges for U.S. Importers

Tax Alert

03.12.2025

Firm Publication

District Court Confirms Prior FedEx Ruling Is Unaffected by Loper Bright and Rejects New Argument from the DOJ

Tax Alert

03.12.2025

Firm Publication

Trump Administration Prompts Treasury to Target Foreign Extraterritorial and Discriminatory Taxes

Tax Alert

02.14.2025

External Publication

Reframing the Questions Surrounding the Application of Code Sec. 245A to Controlled Foreign Corporations

02.13.2025

Firm Publication

IRS Clarifies Position on the Periodic Adjustment Rules

Tax Alert

02.13.2025

Firm Publication

IRS Applies Section 269 to Check-the-Box and Section 898(c)(2) Elections

Tax Alert

02.13.2025

Firm Publication

Treasury and the IRS Release Foreign Tax Credit Guidance for Digital Content Transfers and Cloud Services Transactions

Tax Alert

02.13.2025

Firm Publication

Final Regulations Target Disregarded Payment Losses

Tax Alert

02.13.2025

Firm Publication

Private Letter Ruling Provides Insight into FDII Rules for General Services Income

Tax Alert

01.16.2025

Firm Publication

U.S. Signals Intent to Adopt OECD Transfer Pricing Method for Baseline Marketing and Distribution Activities

Tax Alert

01.16.2025

Firm Publication

Bruyea Confirms Treaty-Based Foreign Tax Credits for the NIIT

Tax Alert

01.16.2025

Firm Publication

Treasury and IRS Publish Final Section 987 Regulations

Tax Alert

01.16.2025

Firm Publication

U.S. Maintains Compliance Under OECD Tax Ruling Exchange Framework

Tax Alert

12.12.2024

Firm Publication

Treasury and IRS Release Long-Awaited Proposed Regulations on Previously Taxed Earnings and Profits

Tax Alert

12.12.2024

Firm Publication

MAP and APA Proceedings Remain a Successful Option for U.S. Taxpayers Operating in an Increasingly Complex World

Tax Alert

11.04.2024

Firm Publication

IRS Memorandum Applies Section 246(b) Taxable Income Limitation to Section 250 GILTI and FDII Deduction

Tax Alert

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publications

Tax Court Issues Split Ruling in Facebook

Applying Transfer Pricing Principles to Determine Customs Value on Which Tariffs Are Imposed

Collateral Issues Dominate in Final Briefing for Varian and Sysco

Using the First Sale Rule to Reduce Tariffs

Tariff Increases Create Transfer Pricing Challenges for U.S. Importers

District Court Confirms Prior FedEx Ruling Is Unaffected by Loper Bright and Rejects New Argument from the DOJ

Trump Administration Prompts Treasury to Target Foreign Extraterritorial and Discriminatory Taxes

Reframing the Questions Surrounding the Application of Code Sec. 245A to Controlled Foreign Corporations

IRS Clarifies Position on the Periodic Adjustment Rules

IRS Applies Section 269 to Check-the-Box and Section 898(c)(2) Elections

Treasury and the IRS Release Foreign Tax Credit Guidance for Digital Content Transfers and Cloud Services Transactions

Final Regulations Target Disregarded Payment Losses

Private Letter Ruling Provides Insight into FDII Rules for General Services Income

U.S. Signals Intent to Adopt OECD Transfer Pricing Method for Baseline Marketing and Distribution Activities

Bruyea Confirms Treaty-Based Foreign Tax Credits for the NIIT

Treasury and IRS Publish Final Section 987 Regulations

U.S. Maintains Compliance Under OECD Tax Ruling Exchange Framework

Treasury and IRS Release Long-Awaited Proposed Regulations on Previously Taxed Earnings and Profits

MAP and APA Proceedings Remain a Successful Option for U.S. Taxpayers Operating in an Increasingly Complex World

IRS Memorandum Applies Section 246(b) Taxable Income Limitation to Section 250 GILTI and FDII Deduction

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