Searching Content indexed under Corporate Tax by Bernie Pistillo ordered by Published Date Descending.
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Trump Administration Officials And Congressional Leaders Release "Unified Framework" For Tax Reform
Similar to a one-page plan previously released by the Trump administration back in April, the Framework sets forth a sweeping set of potential tax reform objectives but is lacking in substantive detail.
United States
5 Oct 2017
IRS Issues Final Debt-Equity Regulations
The Proposed Regulations have been the subject of significant controversy and provoked an outcry from practitioners, congressional hearings, and over 29,600 comments.
United States
4 Nov 2016
Latest Treasury Action On Inversions Upends Pending Transactions And Surprises Many For Its Broad Scope And Use Of Questionable Authority
On April 4, 2016, the Treasury Department and the Internal Revenue Service issued a sweeping package of new regulations intended to curtail inversion transactions
United States
27 Apr 2016
The Inversion Craze: Will Today's Routine Tax Planning Be Retroactively Outlawed?
The media have been abuzz with reports on the latest so-called "inversion" transactions shifting a U.S.-based multinational corporation’s tax residence offshore.
United States
28 Jul 2014
Recently Proposed Treasury Regulations Regarding The Allocation Of Partnership Recourse And Nonrecourse Liabilities Contain Significant Changes For Many Routine Partnership Transactions
On January 29, 2014, the Internal Revenue Service and the Treasury Department issued proposed regulations modifying the rules under Section 752 regarding the allocation of recourse and nonrecourse partnership liabilities and clarifying some aspects of the disguised sale rules of Section 707.
United States
17 Feb 2014
Managing Offshore Holding Companies From China: Recent Case May Suggest Increased Tax Risk
As our readers know, foreign investments into the People’s Republic of China ("PRC") are typically structured through one or more holding companies domiciled in offshore jurisdictions.
4 Nov 2013
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