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GILTI as (Dis)charged: Modifications and discharges of debt issued by CFCs can cause income inclusions for US shareholders under Tax Reform

USA - March 12 2018 Prior to the effectiveness of the global intangible low-taxed income ("GILTI") provisions of the "Tax Cuts and JOBS Act" (the "Act"), modifying or...

Mark Schwed, Andrew J. Yoon, Eric Remijan.

After Tax Reform, Should Your Multinational Group Be US Parented?

USA - January 5 2018 Prior to the December 2017 enactment of the "Tax Cuts and Jobs Act" (the "Act"), common tax wisdom was to avoid placing international operations under...

Michael Rivkin, Kimberly Blanchard.

IRS issues more rules affecting inversions

USA - September 29 2014 On September 23, the IRS issued long-promised rules intended to discourage U.S. companies from being acquired by foreign companies in so-called...

Kimberly Blanchard.