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Searching Content indexed under Income Tax by Fenwick & West LLP ordered by Published Date Descending.
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1
The BEAT Proposed Regulations: Use Of Common Law Doctrines
With its new reach, the Base Erosion and Anti-Abuse Tax ("BEAT") under Section 59A has now come into sharp focus for many large corporate taxpayers, particularly in light of the phase in of the 10%
United States
29 May 2019
2
Proposed FDII Regulations Bring Some Clarity
On March 4 Treasury and the IRS released the highly anticipated proposed foreign-derived intangible income regulations (REG-104464-18) under section 250.
United States
29 Apr 2019
3
Treasury And IRS Propose Welcome (And Some Unwelcome) Guidance On The Base Erosion And Anti-Abuse Tax
Treasury and the IRS have issued proposed regulations filling a number of gaps and providing necessary guidance on the Base Erosion and Anti-Abuse Tax (BEAT).
United States
17 Jan 2019
4
The High-Taxed Exception And E&P Limitation To Subpart F Income
Subpart F has long included exceptions to subpart F income for income of controlled foreign corporations ("CFCs") subject to a relatively high rate of foreign tax and limited subpart F inclusions to the current earnings and profits ("E&P") of the CFC.
United States
9 Jan 2019
5
IRS Issues New Guidance On Section 83(i)
The test is not whether 80 percent received either options or RSUs.
United States
27 Dec 2018
6
The New Foreign Tax Credit Proposed Regulations – An Executive Summary
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts
United States
18 Dec 2018
7
US Taxation Of IP After Tax Reform
U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury are still figuring out...
United States
13 Jul 2018
8
International Tax Reform For US Individuals And Pass-Through Entities (Video)
The recent Tax Cuts and Jobs Act has revolutionized the U.S. taxation of international income earned from outbound investment and business operations.
United States
17 May 2018
9
IRS Filing And Reporting Requirements For ISO Exercises And ESPP Stock Transfers - January 12, 2018
This client alert is intended to remind you of certain 2017 year-end reporting requirements under Section 6039 of the Internal Revenue Code of 1986, as amended (the Code)...
United States
15 Jan 2018
10
A Concise Summary Of The New Tax Law
Those far-off changes are not addressed in this summary.
United States
8 Jan 2018
11
Congress Approves Tax Reform Bill Impacting Equity Compensation
The Tax Cuts and Jobs Act was passed by both chambers of Congress on Wednesday, December 20, 2017, and will be sent to the President's desk for final signature.
United States
22 Dec 2017
12
Revised Senate Tax Reform Bill Represents Win for Technology Sector
Paving the way for a net-win for technology companies, Senate Finance Committee Chairman Orrin Hatch (R-Utah) released a modified chairman's mark to the Tax Cuts and Jobs Act ...
United States
20 Nov 2017
13
Update: Proposed Tax Reform Bill As Amended Stands To Significantly Impact Equity And Performance-Based Compensation
The House Ways and Means Committee on November 2, 2017, released the proposed Tax Cuts and Jobs Act, which may have significant impact on the taxation of equity and performance-based compensation ...
United States
10 Nov 2017
14
Proposed Tax Reform Bill Stands To Significantly Impact Equity And Performance-Based Compensation
The House Ways and Means Committee on November 2, 2017, released the proposed Tax Cuts and Jobs Act, which may have significant impact on the taxation of equity and performance-based compensation ...
United States
7 Nov 2017
15
Recent Tax Court Decision In Crestek – A Cautionary Tale For U.S. Companies With Foreign Subsidiaries
A planning objective that may be very important​ for a U.S. corporation (or other controlling U.S. shareholder) with foreign subsidiaries is deferral of U.S. tax on the un-repatriated earnings...
United States
5 Sep 2017
16
IRS Filing And Reporting Requirements For ISO Exercises And ESPP Stock Transfers
This Client Alert is intended to remind you of certain year-end reporting requirements under Section 6039 of the Internal Revenue Code of 1986, as amended . . .
United States
16 Jan 2017
17
AM 2015-01—Does Previously Taxed Income "Tier Up" To A Domestic Corporate Shareholder?
In a recent chief counsel memorandum (AM 2015-01), the IRS addressed a long uncertain tax question.
United States
9 Apr 2015
18
Section 83(b) Election - Better Safe Than Sorry
If you received or are about to receive restricted stock in connection with the performances of services, you should consider making a timely § 83(b) election in the US.
United States
10 Jun 2014
19
FTB Disallows California Qualified Small Business Stock Benefits
The California Franchise Tax Board has recently issued FTB Notice 2012-03.
United States
11 Feb 2013
20
DOJ Targets Approximately 20,000 Investors As Co-Conspirators In Criminal Tax Fraud Investigation Of UBS
The United States Department of Justice has opened a new front on its war against allegedly fraudulent tax shelters. On November 12, 2008, the United States indicted a senior executive at UBS AG for tax evasion.
United States
3 Dec 2008
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