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We expect recently-issued proposed regulations under Section 409A of the Internal Revenue Code, along with recent changes in financial accounting rules and practices, to significantly and immediately affect the way in which private companies set the exercise prices for their stock options and values for other stock-based compensation.

On November 26, 2018 the U.S. Department of Treasury and the IRS released proposed regulations that provide guidance on the limitation on the business interest expense deduction for certain taxpayers.

Our recent blog post, The First Sale Doctrine: A Strategic Tool for Reducing Tariffs—But Only If You Do It Right, generated a lot of questions.

Prior to the Tax Cuts and Jobs Act of 2017 ("TCJA"), the appeal of cost sharing was driven largely by the deferral of U.S. taxation on foreign earnings.

October brought several important developments in the telecommunications world, including final approval by the Department of Justice and Federal Trade Commission of mergers involving the four largest local and long-distance telephone companies in the United States. The FCC also responded to the aftermath of Hurricane Katrina, and fallout continued from the Commission’s Triennial Review Remand Order. These and other events are covered here, along with our usual list of deadlines for your calenda

LLCs may be treated as either a partnership or a corporation for U.S. tax purposes depending on various factors. Therefore, special care must be taken to ensure partnership status if desired. (See Section 4.4 for a discussion of the manner of determining the tax status of LLCs.)

The Organisation for EconomicCoordination and Development released its highly anticipated Action Plan on Base Erosion and Profit Shifting, which was then unanimously approved by the G-20 Finance Ministers at their July 20, 2013 meeting in Moscow.

The period from the early 1980s through mid-2008, during which many transfer pricing methods and their application matured, was one of generally strong profitability for multinational companies.

The U.S. Treasury Department and IRS have issued proposed regulations addressing two significant changes to the Internal Revenue Code made under the One Big Beautiful Bill Act: the allocation of foreign income taxes following the repeal of the one-month deferral election for controlled foreign corporations, and the new partial foreign tax credit disallowance on certain previously taxed earnings and profits distributions. These regulations introduce four new elections that provide taxpayers with greater flex

This opinion regards a transfer pricing, comparable uncontrolled transaction.

One aspect of the new Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (BAPCPA) that has received little attention in bankruptcy law circles or in the media is the impact of BAPCPA on the treatment of securities and derivatives transactions in bankruptcy.

Explore the latest tax developments across 12 Asian jurisdictions, including China's offshore trust regulations, Hong Kong's corporate treasury incentives, and India's safe harbour reforms for offshore funds. Discover how regional governments are reshaping tax frameworks through e-invoicing mandates, transfer pricing updates, and strategic incentives designed to attract investment and enhance competitiveness.

Part I of this article summarized the basic concepts underpinning derivatives transactions and outlined the provisions in the Bankruptcy Code (Financial Market Provisions) where these types of transactions and securities transactions are accorded special treatment.

Following the lead of the O.E.C.D. and the European Commission ("E.C."), the Tax Cuts and Jobs Act ("T.C.J.A.") adopts several provisions designed to end certain tax planning opportunities.

This article covers recent tax developments in Canada, Chile, Mexico and The United States.

The Internal Revenue Service's determination of transferee liability, essentially secondary liability, resulting from transactions involving the taxable sale and disposition of corporate stock...

On July 3, 2018, the Organisation of Economic Co-operation and Development ("OECD") released the first public discussion draft on the transfer pricing of financial transactions.