Searching Content indexed under Tax by Lewis Greenwald ordered by Published Date Descending.
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Treasury And The IRS Introduce Significant Changes In The Final Section 385 Regulations On Intercompany Debt
This legal update provides a brief summary of the most significant changes included in the Final Regulations.
United States
17 Oct 2016
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
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
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
Reg. § 1.482-1(a)(3): Has The Ship Sailed With Intersport?
As long as there is nothing expressly prohibiting the adjustment, taxpayers may generally file amended returns reporting an amount of tax owed that is less than what they had previously reported on their originally filed return.
United States
30 Dec 2014
Significant Progress Made On The OECD’s BEPS Action Plan
This Legal Update is the second in a series that Mayer Brown Tax lawyers are publishing on key developments at the national and international levels related to the Organisation for Economic Co-Operation and Development’s ("OECD") Action Plan on Base Erosion and Profit Shifting (the "BEPS Action Plan").
10 Mar 2014
An "Available Upon Request" GRA Is A Willful Failure
Since 1986, the U.S. Treasury Department regulations promulgated under section 367(a) of the Internal Revenue Code have provided a reasonable cause exception for gain recognition agreement compliance failures.
United States
17 Sep 2013
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