Searching Content by Lucas Giardelli ordered by Published Date Descending.
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Treasury Releases Proposed Regulations On Foreign Tax Credits Under New International Tax Rules
On November 28, 2018, the US Department of Treasury and Internal Revenue Service released proposed regulations on the determination of foreign tax credits
United States
27 Dec 2018
High-Level Overview Of The Proposed Regulations On Interest Deduction Limitation Rules
On November 26, 2018, the Department of Treasury and US Internal Revenue Service released proposed regulations that flesh out the new Section 163(j) interest limitation rule
United States
4 Dec 2018
Can You Simply Remove GILTI Income From Your State Tax Base (New York And Elsewhere)?
The New York State 2018 legislative session included a couple bills, including a State Senate draft of the budget bill ...
United States
26 Sep 2018
GILTI Pleasures: The IRS Releases Proposed Regulations On Global Intangible Low-Taxed Income
Every one of us has some guilty pleasure, whether it's watching soap operas, binging on jelly donuts, attending electronic dance music parties ...
United States
26 Sep 2018
Examining The Proposed U.S. Country-By-Country Reporting Regs
Following the OECD recommendation under the BEPS project, in December 2015 the U.S. Treasury issued proposed regulations on country-by-country reporting.
United States
5 May 2016
Treasury's New Anti-Inversion Regulations: Do They Go Too Far?
On April 4, the US Treasury and the IRS issued extensive proposed and temporary regulations described as curbing inversions and addressing earnings stripping.
United States
11 Apr 2016
The IRS And Treasury Issue New Anti-Inversion Notice
On November 19, 2015, the US Internal Revenue Service and the Treasury Department issued Notice 2015-79, announcing their intention to expand on previously issued guidance concerning inversions and post-inversion transactions.
United States
2 Dec 2015
The Difficulty Of GLAM 2015-002's Five-Step Approach
With the promulgation of the check-the-box regulations and the proliferation of branches (for U.S. tax purposes), a number of U.S. international tax provisions gained significantly in importance.
United States
23 Sep 2015
A Matter Of Semantics: Validus Reinsurance Invalidates Foreign-To-Foreign Withholding
President Bill Clinton famously attempted to come to terms with the meaning of the verb "is" when he was caught engaging in hanky-panky at the White House: "It depends on what the meaning of the word 'is' is.
United States
30 Jun 2015
Final GRA Regulations Make Noteworthy Changes To Proposed Regulations
On November 18, 2014, the IRS and Treasury released final regulations addressing compliance failures relating to gain recognition agreements.
United States
6 Feb 2015
IRS And Treasury Issue Long-Awaited Guidance On Corporate Inversions And "Disqualified Stock"
On January 16, 2014, the Internal Revenue Service (the "IRS") and the Treasury Department (the "Treasury") issued longawaited temporary and proposed regulations under Code section 78741 relating to corporate inversions (the "Regulations").
United States
30 Jan 2014
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