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United States: Final and Proposed Regulations Issued for GILTI and Subpart F High-Taxed Income - Observations for Individual U.S. Shareholders

USA - August 20 2020 On July 23, 2020, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) published final regulations under Section 951A…

Jeffrey L. Rubinger, Megan Ferris, Robert H. Moore, Simon P. Beck.

United States: Benefits of selling foreign IP to a related or unrelated foreign party under the FDII tax regime

USA - May 29 2020 The foreign-derived intangible income (FDII) rules have created opportunities for foreign corporations to cause their US subsidiaries to sell their…

Abrahm William Smith, James H. Barrett.

US: Some Family Planning Opportunities Amidst Crisis

USA - May 13 2020 On Wednesday, April 29th, 2020, the U.S. Bureau of Economic Analysis (BEA) released data showing that the United States economy shrank in Real GDP…

David Berek, James Gifford.

Corporation and Charitable Foundation Grants During the COVID-19 Pandemic

USA - March 27 2020 This alert discusses various strategies for corporations and corporate foundations to assist in the fight against the COVID-19 pandemic through grants…

Glenn G. Fox, Olga Sanders, Paul F. DePasquale, Simon P. Beck.

Tax News and Developments North America-October 2019

USA - November 3 2019 It's full steam ahead with the IRS's Office of Appeals ("Appeals") initiative (the "Appeals Initiative") to allow Exam Teams to participate in the…

Cameron Reilly, Donna McComber, Joseph Volk, Joshua D Odintz, Karl Egbert, Kent P. Stackhouse, Lyubomir Georgiev, Mireille R. Oldak, Richard (Dick) M. Lipton, Rob Galloway, Steven R. Schneider.