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Today in Tax: Model Global Minimum Tax Rules and Gain Exclusion for Software Companies
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...
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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: Eligibility of Electronic Services Income for FDII Deduction
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...
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Today in Tax: Foreign Account Reporting Requirements and Divisive Tax-Free Reorganizations
Brief commentary on cases, rulings, notices, and related federal tax guidance as of December 29, 2021.
FBAR Noncompliance Leads to More Severe Penalties in the 5th Circuit
Penalties for FBAR violations can be severe if applied on a per-account basi...
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Today in Tax: Foreign Tax Credits Against Digital Service Taxes, Partial Spin-Off Structures, and Filing Relief for Equity Grants, Stock Sale Structuring, and Opportunity Zones
Brief commentary on recent cases, rulings, notices, and related federal tax guidance as of December 14, 2021.
U.S. Agreements Expand Potential Tax Credits for Digital Service Taxes
The global tax landscape is rapidly changing as countries around th...
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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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