Articles

US companies often have commercial transactions with their overseas affiliates in the form of financing, supply, manufacturing, services, or other agreements. Each of these common intercompany transactions can be the cause of significant US or foreig...

For a printable PDF version of this article, please click here. The global economy is becoming increasingly integrated, and companies are routinely able to access markets throughout the world. For decades, the United States has maintained a robust e...

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Jarrett Case Raises New Questions on How to Report Cryptocurrency “Staking” Rewards While the IRS has not specifically addressed the taxation of staking rewards,...

Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Model Rules for a Global Minimum Tax Companies should start preparing for the implementation of the OECD’s global minimum tax regime. Importantly, while...

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Transition rules allow opportunity to avoid taxable income when modifying financial contracts from IBOR to another metric Contracts dependent on a discontinued in...

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Regulations open door for cloud computing, streaming, and related electronic services to be included in deduction computation. In late 2017 the Tax Cuts and Jobs...