All Articles
Today in Tax: Financial Contract Modification and Foreign Tax Credits
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...
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Today in Tax: Qualified Small Business Stock, Opportunity Zones, Information Reporting for Digital Assets
A brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance.
Medical Software Deemed a Qualifying Trade for Qualified Small Business Stock Gain Exclusion
When certain criteria are met, stockholders may be able to...
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When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce in the United States (Part 2)
Introduction
Part 1 of this series discussed the proposals adopted by various countries to impose taxes on the digital economy, particularly by taxing various types of digital advertising and other digital services. These taxes allow countries to re...
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When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce across the Globe (Part 1)
The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social media platforms in the 2000’...
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