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Searching Content indexed under Tax Authorities 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
2
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
3
IRS Filing And Reporting Requirements For ISO Exercises And ESPP Stock Transfers For 2019
This client alert is intended to remind you of certain 2018 year-end reporting requirements under Section 6039 of the Internal Revenue Code of 1986, as amended (the Code)
United States
24 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
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
6
Impact Of Tax Reform On The Purchase And Sale Of Controlled Foreign Corporations — Selected Considerations
The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted...
United States
20 Sep 2018
7
New 162(m) Guidance: IRS Notice 2018-68 Clarifies Scope Of Tax Reform And Transition Rules
Section 162(m) of the Internal Revenue Code denies a tax deduction to a public company for compensation paid to certain individuals—called "covered employees"—to the extent that the compensation paid
United States
3 Sep 2018
8
IRS Notice 2018-26: Important New Guidance On The Mandatory Repatriation Tax
This document discusses Notice 2018-26, the third IRS Notice providing guidance on the new mandatory repatriation tax under § 965.
United States
11 Apr 2018
9
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
10
Equity Compensation Rules Continue To Change In Latest Proposed Tax Reform Bill
The tax reform bill passed by the Senate early Saturday morning, December 2, in a 51-49 vote contained a number of last-minute amendments which, among other things ...
United States
7 Dec 2017
11
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
12
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
13
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
14
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
15
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
16
Fenwick's Top 10: Our Most Popular Articles Of 2016
From the watershed Brexit vote that put the United Kingdom on course to leave the European Union to the hottest developments in venture financing, SEC enforcement and IP law..
United States
13 Jan 2017
17
Transfer Payments For Offshored Patents Can Invite IRS Scrutiny And Hinder Patent Damages Claims
Tax inversions and the offshoring of intellectual property by U.S. companies grew from an arcane tax law subject to a popular election year issue this autumn.
United States
21 Nov 2016
18
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
19
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
20
Executive Compensation And Employee Benefits Alert: 2015 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.
United States
6 Jan 2016
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