Articles

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. The Billionaire Minimum Income Tax in Biden’s 2023 Budget Proposal Biden’s proposed “top-up” tax on wealthy individuals would ensure that households worth more th...

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. IRS Introduces Fast-Track Process for Obtaining Letter Rulings Corporate reorganizations and spin-off transactions are transactions where there is often...

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...