Searching Content indexed under Tax Treaties by McDermott Will & Emery ordered by Published Date Descending.
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Chairman Brady Introduces Long-Awaited Bill Including Comprehensive Business Tax Reform Provisions
The newly introduced Tax Cuts and Jobs Act is a comprehensive tax reform package that touches virtually every area of the tax law.
United States
8 Nov 2017
Washington ALJ Upholds B&O Assessment On German Company's Royalty Income
On May 31, 2016, the Washington Department of Revenue Appeals Division released a Determination denying a German pharmaceutical company's business and occupation tax protest.
United States
20 Jun 2016
International Tax Disputes: A Ray Of Hope
Despite the anticipated tsunami of tax disputes generated by underlying tensions in international taxation, there is reason for hope that appropriate means are being developed to address them efficiently and effectively.
United States
29 Jan 2016
City Of Chicago Debt Relief Program – A Tax Amnesty Opportunity
Chicago's Department of Finance currently is offering an amnesty program called the Debt Relief Program (Program).
United States
10 Dec 2015
U.S. International Tax Policy: 10 Questions For 2015
The year 2015 promises to be an active one in U.S. international tax policy.
United States
5 Mar 2015
FATCA Primer For Non-Financial Enterprises
FATCA went into effect on July 1, 2014, after numerous delays and multiple rounds of administrative guidance.
United States
12 Nov 2014
International Taxation Controversy: The Coming Storm
There is a revolution underway in the world of international taxation.
United States
17 Mar 2014
IRS Issues Final Subpart F Branch Rule Regulations
Income derived by a foreign subsidiary of a U.S. corporation from the sale of products is not generally subject to U.S. taxation on a current basis.
United States
6 Jan 2012
Achieving a Smooth Stock Basis
In a helpful recent private letter ruling, the Internal Revenue Service illustrated a method allowing multinational corporations seeking tax-efficient ways to repatriate offshore cash to avoid the obstacle posed by Johnson v. United States.
United States
1 Dec 2010
Puerto Rico Enacts New Excise Tax That Impacts U.S. Companies
A temporary excise tax recently enacted in Puerto Rico will have a significant impact on U.S.-based multinational groups conducting, or considering conducting, manufacturing activities in the country.
United States
8 Nov 2010
Congress Enacts International Tax Legislation, Limits Use of Foreign Credits
On August 10, 2010, President Obama signed the Education Jobs and Medicaid Assistance Act of 2010 into law.
United States
10 Sep 2010
Private Letter Ruling Issued Addressing the Public Benefit Exception Under IRC Section 118(b) Relating to Contributions in Aid of Construction
A Private Letter Ruling, particularly important to utility companies that receive payments to facilitate the relocation of transmission equipment, was recently issued.
United States
23 Jul 2010
Procter & Gamble Wins Summary Judgment in Important Research Credit Case
U.S. District Court rules in company’s favor and determines all members of a controlled group of corporations should be treated as a single taxpayer when calculating research credits.
United States
14 Jul 2010
TPG Capital, Vodafone, China Notice 698 and Beyond: Local Country Taxation of Transfers of Stock Involving Tiered Structures
From time to time in the course of our practice we have encountered and informed clients about developments in matters of international taxation in various non-U.S. jurisdictions.
United States
28 Apr 2010
U.S. Tax Court Holds That Guaranty Fee Is Sourced To Location Of Guarantor
The Tax Court's decision in Container Corp. v. Comm'r will have a significant impact on U.S. corporations that guarantee loans to foreign subsidiaries.
United States
8 Mar 2010
Concessions For Delinquent Information Returns Pertaining To Certain Offshore Investments Other Than FBAR Form TD F 90-22.1
The IRS has indicated that it will waive failure to file penalties with respect to delinquent Forms 5471 and similar information returns, in situations where foreign income has been reported and taxes paid, provided such filings are made by September 23, 2009.
United States
26 Aug 2009
IRS Temporarily Liberalizes Section 956 In An Effort To Facilitate Corporate Liquidity
By temporarily liberalizing section 956, the IRS seeks to aid companies facing challenges as a result of illiquidity in the commercial paper and other key credit markets.
United States
24 Oct 2008
Proposed Regulations Provide Comprehensive Guidance On Subpart F Contract Manufacturing Issues
On February 27, 2008, the Treasury Department (Treasury) and the Internal Revenue Service (the Service) released proposed regulations that provide comprehensive guidance on the treatment of contract manufacturing arrangements under the foreign base company sales income (FBCSI) rules of subpart F.
United States
2 Apr 2008
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