After a cross-border merger or acquisition, related affiliates often integrate and use the acquired intangibles, such as new ...
Even though recent changes substantially reduced abuse concerns, U.S. corporate shareholders must still comply with the extraordinary reduction rules when deducting certain foreign dividends.
Jorge Olavarrieta. vice president and general manager, ProTax Group, Intuit, discusses how leading tax firms actually make advisory work. AICPA members in tax practice assess how their return ...
Focusing on private-equity acquisitions, this article compares merger forms and highlights tax considerations, particularly ...
Thresholds and ceilings for individual and corporate deductions under the law known as the One Big Beautiful Bill Act may ...
Foreign companies can realize benefits from establishing domicile in the United States if they observe structural and special ...
Acquaintance with relevant Internal Revenue Manual provisions can aid practitioners in protecting clients’ rights in tax ...
Hyatt appealed the Tax Court’s decision to the Seventh Circuit. On appeal, Hyatt renewed its arguments that the payments into ...
Tax Court disallows part of a taxpayer’s Sec. 245A dividends-received deduction and holds post–Sec. 965(c) amount must be ...
Taxpayers issuing related-party loans should assess the consequences if those debt instruments are determined to have a zero ...
Practitioners must observe and protect time limits for requesting a refund, administrative appeals, and litigation.
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