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Our client is a US-based technology company. The client had substantial presence in India earlier and now was in the process of winding up its operations.

Because of the uncertainty over the future of the federal estate, gift and generation-skipping transfer (GST) tax exemptions through the end of last year, many individuals made significant taxable gifts to trusts for their families in an attempt to capture the then current $5,120,000 federal exemption amounts before a possible decrease.

In November, the IRS Office of Chief Counsel issued a generic legal advice memorandum ("GLAM") AM-2022-006, titled "Realistic Alternatives and Tax Considerations in the Application of Sections...

The IRS has added and modified several international guidance projects in the 2016‒2017 Priority Guidance Plan.

Three is the number of major election forecasting models predicting a likelihood that Republicans will win the six Senate seats needed to secure a majority.

The federal estate and generation-skipping transfer taxes were repealed as of January 1, 2010. Consequently, no federal estate tax will apply to estates of individuals dying in 2010 and no generation-skipping transfer tax will apply to transfers made in 2010.

On August 2, 2016, the Treasury Department and the IRS issued proposed regulations under section 2704 of the Internal Revenue Code of 1986, as amended.

On September 1, 2020, the IRS issued final regulations regarding the base erosion and anti-abuse tax codified in IRC §59A.

On September 24, 2019, the General Court of the European Union released its decisions on two major State Aid cases.

In October 2015, the Organization for Economic Cooperation and Development (OECD) finalized its report titled Action 14: Making Dispute Resolution Mechanisms More Effective.

The Development: The EU General Court annulled the European Commission's decision in the Apple case, holding that the Commission did not prove that the Irish tax rulings in question...

A recent opinion in the bankruptcy case of Enron Corporation provides some insight into counterparties’ eligibility for the protections of the safe harbor provisions of the Bankruptcy Code.

In einer Übernahme ist der Verrechnungspreis im Prinzip verhandelbar. Wenn jedoch der vereinbarte Preis weniger ist als der Nennwert der Stammeinlage des Verkäufers zum...

Suppose you sell or exchange your appreciated low basis privately-held company stock for equivalent publicly traded stock in a "tax-free reorganization," but for various reasons you do not want to sell the publicly traded stock in your current tax year.

The tax rate will double to 10% for the years 2019 through 2025, with a further increase to 12.5% after 2025.

Chilean tax authorities recently adopted a three-tiered approach to transfer pricing documentation. Chile is one of the few Latin American countries...

Delaware Statutory Trusts (DSTs) continue to grow in popularity as a passive real estate investment vehicle — especially for investors seeking a streamlined option in a 1031 exchange.

The IRS released a private letter ruling that held that the acquisition of substantially all the assets of a transferred corporation results in the termination of the associated gain recognition agreement under Section 367.