439 results found

H. David Rosenbloom examines the complexities of Pillar Two and the "Side-by-Side" Agreement in international tax law, providing clarity on these intricate mechanisms. This analysis explores the technical framework and implications of these global tax reform measures for multinational enterprises and tax practitioners.

H. David Rosenbloom co-authored an article examining the international tax provisions of the OBBBA legislation, providing a comprehensive nutshell explanation of these complex regulatory measures. The piece offers detailed analysis of how these provisions impact cross-border taxation and international tax planning strategies.

As described in a previous Caplin & Drysdale Political Activity Law Alert, a March 20, 2009 Memorandum from President Obama imposed various restrictions on the interactions between lobbyists and the executive branch of the federal government, including: (1) barring registered lobbyists from having oral communications with government officials about specific American Recovery and Reinvestment Act ("ARRA") projects or applications and (2) requiring online disclosure of communications between regis

Four decades after the campaign finance reforms that followed Watergate, arguments over the role of money in politics seem increasingly tired and unproductive.

Clark Armitage, David Rosenbloom, and Arjun Ghosh co-wrote the article "Is ICAP a Viable Alternative to APAs?" for IBFD International Transfer Pricing Journal 2023 in Volume 30, No. 5.

Peter Barnes wrote the article "Turning Point: A Century of International Tax Policy Flies toward a Sharp Curve" for IBFD Talking Points.

The U.S. Supreme Court announced its decision today in the high-profile case U.S. v. Windsor, overturning the Defense of Marriage Act.

Last week, the Federal Election Commission announced updated contribution limits for the 2011-2012 election cycle.

Leila Carney authored "Entrepreneur or Hobbyist: Turning Losses Into a Win" in the January 2023 issue of Thomson Reuters journal Practical Tax Strategies.

This article examines certain provisions of the current Korea-U.S. Income tax treaty and suggests possible amendments based on the 2006 U.S. model treaty.

The "GILTI Conscience" podcast team, led by Skadden partners David Farhat and Nate Carden, hosted Clark Armitage of Caplin & Drysdale for an in-depth conversation...

What are current trends in US tax disputes? How can you reduce litigation risk? What is the Supreme Court likely to make of Moore, a case that could call into question large swathes of the US tax system?

A medical and adult-use cannabis dispensary operator in Illinois has filed a U.S. Tax Court petition challenging nearly $1.6 million in IRS assessments and penalties, marking one of the first publicly reported attempts to argue that federal marijuana rescheduling affects the application of Internal Revenue Code Section 280E. The case tests whether rescheduling changes tax treatment for prior years, potentially reshaping how cannabis businesses handle federal tax obligations.

A proposal by the Mayor of New York City to change the City's corporate tax structure would, for the first time, tax certain businesses that have no physical presence in New York City but that do business in the City or with City residents.

Effective January 1, 2013, the District of Columbia will no longer exempt the income on municipal bonds issued by all municipalities.

Effective January 1, 2012, the District of Columbia will no longer exempt the income on municipal bonds issued by all municipalities.

Remarkably on schedule, the OECD this week issued a comprehensive and integrated set of measures to attack base erosion and profit shifting on a global basis.

On January 3, 2024, the Department of Justice announced that Barry Bennett and Douglas Watts entered into Deferred Prosecution Agreements.