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Taxpayers Already Seeking to Hold Treasury and IRS to Policy Statement

USA - March 20 2019 On March 5, 2019, the US Department of Treasury (Treasury) issued a policy statement on the tax regulatory process. We previously wrote an article for...

Andrew R. Roberson.

Government Files Its Brief in Auer Deference Case

USA - February 27 2019 As we discussed in a prior post and in our article for Law360, the Supreme Court is poised to decide in Kisor v. Wilkie whether to overrule the Auer...

Andrew R. Roberson.

Proposed Regulations under Section 956 Provide Benefits for Corporate Taxpayers

USA - November 20 2018 On October 31, 2018, the Internal Revenue Service (IRS) and US Department of the Treasury (Treasury) released proposed regulations (REG-114540-18)...

Bradford E. LaBonte, Lowell D. Yoder.

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...

Jonathan Lockhart, Lowell D. Yoder, Michael J. Wilder.

Selling CFC Stock: A Buyer’s Section 338 Election Can Be Beneficial

USA - November 1 2018 Following the 2017 Tax Act, a domestic corporate purchaser of stock in a controlled foreign corporation (CFC) generally will desire to make a section...

Jonathan Lockhart, Lowell D. Yoder, Michael J. Wilder.