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Recent Tax Court Decision in Crestek - a Cautionary Tale for U.S. Companies with Foreign Subsidiaries

USA - August 29 2017 In a ruling with tax implications for U.S. corporations with foreign subsidiaries, the U.S. Tax Court has held that transactions between a U.S...


IRS untangles section 163(l) in cross-border hybrid financing transaction

USA - May 13 2015 "In terrorem" or anti-abuse provisions often receive a lack of judicial and administrative interpretation. Section 163(l) of the Code, enacted in...


AM 2015-01does previously taxed income “tier up” to a domestic corporate shareholder?

USA - April 8 2015 In a recent Chief Counsel memorandum (AM 2015-01), the IRS addressed a long uncertain tax question: when a US corporate shareholder includes an...

David L.Forst.


Taxation of foreign currency

USA - February 21 2015 This outline provides a plain English summary of the tax provisions of Subpart J of the Code governing the taxation of foreign currency gain or loss...


Commissionnaires and other PE structures under scrutiny as part of BEPS

Global - December 9 2014 The OECD has recently published a discussion draft on the portion of its BEPS action plan dealing with permanent establishments and has titled this...

David L.Forst.