Michael J. Wilder
McDermott Will & Emery
Articles
IRS Releases Memorandum Regarding Advance Payments of Section 367(d) Inclusions
USA - October 19 2022 On September 23, 2022, the Internal Revenue Service (IRS) released a memorandum (AM 2022-003) concluding that taxpayers cannot make advance payments…
IRS Releases Memorandum Regarding Advance Payments of Section 367(d) Inclusions
USA - October 17 2022 On September 23, 2022, the Internal Revenue Service (IRS) released a memorandum (AM 2022-003) concluding that taxpayers cannot make advance payments…
Government Revises Base Difference Rules in New Foreign Tax Credit Regulations
USA - November 3 2020 The 2019 Proposed Regulations provided a detailed framework for allocating and apportioning foreign taxes that was generally…
The GILTI High-Tax Exclusion and the Tested Unit Standard: New Administrative Burdens Await for Taxpayers
USA - August 10 2020 On July 23, 2020, the US Department of the Treasury and the Internal Revenue Service (IRS) published final regulations addressing the global…
Benefits of a Section 338 Election to a US Buyer of CFC Stock
USA - November 15 2018 The 2017 Tax Act significantly increased the benefits of a section 338(g) election for a domestic corporate purchaser of stock in a controlled foreign…
