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Results: 11-20 of 103

The gift of Mayo

  • Baker & McKenzie
  • -
  • USA
  • -
  • February 22 2012

In mid-December, the Supreme Court decided Judulang v. Holder, 565 U.S. ___ (No. 10-694, Dec. 12, 2011), an important immigration case

A wooly mammoth: IRS issues expansive guidance regarding tangible property costs

  • Baker & McKenzie
  • -
  • USA
  • -
  • February 22 2012

This article is simply about timing

IRS issues temporary and final treasury regulations on foreign tax credit splitters

  • Baker & McKenzie
  • -
  • USA
  • -
  • February 22 2012

On February 14, 2011, the IRS published in the Federal Register proposed and temporary regulations under Code Section 909, the foreign tax credit “splitter” legislation enacted on August 10, 2010 (the “Section 909 Regulations”

IRS unveils final regulations on foreign base company sales income related to the branch rules

  • Baker & McKenzie
  • -
  • USA
  • -
  • February 22 2012

The IRS has issued final regulations under Code Section 954 (the “Final Regulations”) addressing foreign base company sales income (“FBCSI”) related to the so-called “branch rules.”

Daily deals and state tax implications

  • Baker & McKenzie
  • -
  • USA
  • -
  • February 22 2012

If you have visited the internet lately any old website with banner ads is usually enough then you have likely been exposed to the web-based phenomenon that is the “daily deal.”

IRS issues final conduit financing regulations involving disregarded entities

  • Baker & McKenzie
  • -
  • USA
  • -
  • February 22 2012

Treasury has issued final regulations under Code Section 881 addressing financing arrangements where one of the parties to the transaction is a disregarded entity for US tax purposes

New IRS guidance on FATCA

  • Baker & McKenzie
  • -
  • USA
  • -
  • February 22 2012

On February 8, 2012 the IRS issued Proposed Regulations (“Proposed Regulations”) governing the phased implementation of the Foreign Account Tax Compliance Act (“FATCA”

IRS issues final regulations for cost sharing arrangements

  • Baker & McKenzie
  • -
  • USA
  • -
  • February 22 2012

On January 9, 2012, the North America Tax Practice Group distributed a Client Alert discussing the final regulations for cost sharing arrangements under Code Section 482 ("Final Regulations"), which were issued by the Treasury on December 16, 2011

IRS issues ruling respecting taxpayer’s rescission of corporate reorganization

  • Baker & McKenzie
  • -
  • USA
  • -
  • February 22 2012

At the end of 2011, the IRS issued a private letter ruling that addressed the attempted rescission of a corporate reorganization by a consolidated group of corporations

Practical considerations for sovereign wealth funds in light of the new Section 892 proposed regulations

  • Baker & McKenzie
  • -
  • USA
  • -
  • February 22 2012

On November 3, 2011, the IRS issued proposed regulations (the “Proposed Regulations”) under Code Section 892, the provision that exempts from US Federal income taxation certain qualified investment income derived by foreign governments, including controlled entities of a foreign government such as sovereign wealth funds (“SWFs”

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