Searching Content indexed under Corporate Tax by Fenwick & West LLP ordered by Published Date Descending.
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Multinationals Face An Irrevocable Decision Under The New Section §163j Proposed Regulations
Since the 2017 tax act enacted the new §163(j) limitation on interest deductions, multinationals have been asking whether the limitation applies to controlled foreign
United States
23 Jul 2019
New Field Attorney Advice Explores The Intersection Of § 1253 With The Anti-Churning Rules Of § 197
A new IRS legal advice memorandum addresses a fact pattern that may become more common in the wake of Tax Reform and highlights the potential application of Code § 1253 to change the tax results...
United States
2 Jul 2018
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
What Private Companies & Investors Should Know About Qualified Small Business Stock (Video)
Only certain types of companies qualify under the QSBS rules which are laid out by a statute that aims to encourage entrepreneurial ventures
United States
13 Mar 2018
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
A Concise Summary Of The New Tax Law
Those far-off changes are not addressed in this summary.
United States
8 Jan 2018
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
Proposed Senate Bill Revives Concern Of Adverse Impact On Equity And Performance-Based Compensation
The Joint Committee on Taxation released a description of the Senate Chairman's Mark to the proposed Tax Cuts and Jobs Act on November 9, 2017, reintroducing adverse equity ...
United States
13 Nov 2017
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
Fenwick's Top Articles On Privacy, Patent Venue, Index Rules, SCOTUS And More
Recent months have brought important business, legal and regulatory developments. We analyzed Fenwick's client alerts and rounded up the most popular ones with our readers ...
United States
7 Nov 2017
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
New Intercompany Debt Rules Shock Multinational Companies
On April 4, 2016, the United States Treasury and the Internal Revenue Service ("IRS") issued proposed regulations under §385 of the Internal Revenue Code (the "Code").
United States
6 Jul 2016
Section 385 Proposed Regulations
On April 4, 2016, Treasury and the IRS proposed sweeping regulations under § 385 of the Code.
United States
4 May 2016
Tax Alert: IRS Untangles Section 163(L) In Cross-Border Hybrid Financing Transaction
PLR 201517003 dealt with intercompany debt between a foreign taxpayer, Parent, and its second-tier U.S. subsidiary, Taxpayer.
United States
14 May 2015
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
IRS Filing And Reporting Requirements For ISO Exercises And ESPP Stock Transfers - January 2015
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
14 Jan 2015
Tax Alert: Commissionnaires And Other PE Structures Under Scrutiny As Part Of BEPS
The connective tissue between these two seemingly contradictory statements is a profession by the OECD that all the OECD is trying to do is cure abuse.
United States
12 Dec 2014
New Chief Counsel Memorandum Revisits Definition Of "Obligation" Under IRC Section 956
The IRS chief counsel seemingly exceeded the scope of its own regulations in advising that the amount of a CFC’s section 956 investment included accrued but unpaid interest.
United States
15 Oct 2014
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
New, Severe California Penalties for Taxable Years Before January 1, 2003
Could your company owe income or sales and use taxes in California for tax years beginning prior to January 1, 2003?
United States
25 Aug 2005
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