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  • Article

    Tax Litigation Developments

    Last month, the First Circuit Court of Appeals affirmed the Tax Court's decision in TBL Licensing LLC v. Commissioner holding that a reorganization resulting in the outbound transfer of intangible property (IP)...
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    TAX TAKE: The Greenbook: What Is Missing?

    As policymakers and practitioners analyze the proposals contained in the recently released Treasury Department Greenbook, it is also worth noting what proposals were not included in this important document.
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    IRS Halts New Employee Retention Credit Claims Processing, Previews Settlement Programs

    In a surprising development, the IRS announced on September 14 that it would stop processing new claims for the employee retention credit (ERC). The ERC is a completely refundable employment tax credit that Congress...
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Help! What Happens To My GAO Bid Protest During A Government Shutdown?

    With a pending government shutdown, many government contractors may be asking: What happens to my Government Accountability Office (GAO) bid protest if the government shuts down?
    United StatesGovernment, Public Sector
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Trade Compliance Flash: USTR Accepting Comments On Proposed Section 301 Tariffs In Response To Digital Services Taxes

    In response to Digital Services Taxes (DSTs) implemented in 2020 and 2021 by Austria, Spain, the United Kingdom, India, Italy, and Turkey, the Office of the United States Trade Representative (USTR) is seeking comments...
    GlobalInternational Law
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    TAX TAKE: Top 10 Questions (and Then Some) Regarding The Reconciliation Package: Part One

    As the bipartisan traditional infrastructure package appears on track to pass the Senate and then be considered in the House after the August Congressional recess, tax policymakers will soon turn their complete focus...
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Private Equity ESG – Spotlight On Governance: How Do I Become A Successful Portfolio Company Board Member?

    Being asked to join the board of a portfolio company may initially seem an honor, but PE investment professionals and operating partners need to go into the role with their eyes open.
    United StatesCorporate/Commercial Law
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Trade Compliance Flash: FinCEN And BIS Joint Notice Highlights New Export Evasion Key Term For SAR Reporting And Export Control Evasion Red Flags

    On November 6, 2023, the Department of Commerce's Bureau of Industry and Security (BIS) and the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN)...
    United StatesInternational Law
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    TAX TAKE: After The Fire – Could Another Tax Vehicle Emerge After The House Leadership Crisis?

    The anticipated government shutdown was avoided by the surprise bipartisan continuing resolution (CR), the Continuing Appropriations Act, 2024 and Other Extensions Act...
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    TAX TAKE: Reconciliation Becomes A Reality And Senate Finance Unveils Draft Legislative Text Of Its International Tax Overhaul

    With the House of Representative's narrow passage of the budget resolution the Senate had endorsed the week before, the prospect for passing significant tax provisions via the reconciliation process...
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    DOJ Announces Safe Harbor Policy For Disclosures Of Misconduct Discovered In Acquisition Due Diligence

    On October 4, Deputy Attorney General (DAG) Lisa O. Monaco delivered a speech at the Society of Corporate Compliance and Ethics 22nd Annual Compliance & Ethics Institute announcing...
    United StatesCorporate/Commercial Law
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Treasury And IRS Guidance Explains Transfer Of Clean Vehicle Credits Under Sections 25E And 30D

    This month, Treasury and the IRS released proposed regulations and Revenue Procedure 2023-33 to provide guidance for taxpayers electing to transfer credits under sections 25E...
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Trade Compliance Flash: Proposed New Rule For Country Of Origin Determinations For Products Of Canada And Mexico Could Have Big Implications

    Earlier this month, U.S. Customs and Border Protection (CBP) issued a notice of proposed rulemaking and request for comments that would change the rules for certain country of origin determinations for goods ...
    United StatesInternational Law
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Engel List Names Corrupt And Antidemocratic Actors In Guatemala, Honduras, And El Salvador: What Companies And Investors Should Do Next

    On June 3, 2021, President Biden issued a memorandum declaring corruption as "a core United States national security interest" and directing interagency coordination to develop a presidential strategy to ...
    United StatesCriminal Law
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    TAX TAKE: Senate Taxwriters Have A Few Questions

    While the House of Representatives sits idle as Republicans figure out who to elect as their next Speaker, Senate taxwriters are poring over the written responses to questions for the record (QFRs)...
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    TAX TAKE: New Speaker Mike Johnson Takes The Gavel: Are You Ready For It?

    Representative Mike Johnson (R-LA) was elected Speaker of the House of Representatives last week, winning the vote of every House Republican member and ending a three-week political power impasse.
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    How Multinationals Can Navigate U.S.-China Tensions

    Practical tips for multinational companies to prepare for challenging and evolving regulatory and enforcement landscape in the U.S. and China.
    GlobalInternational Law
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Treasury Releases Long-Awaited Guidance On Capitalization And Amortization Of Specified Research And Experimental Expenditures

    After much anticipation, the U.S. Department of the Treasury (Treasury) and the IRS have finally provided insight into what taxpayers should expect to see in proposed regulations addressing the capitalization...
    United StatesCorporate/Commercial Law
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Making Life (A Bit) Easier For Private Litigants: DoD Issues Proposed Rule To Update Its Touhy Regulations

    The U.S. Department of Defense (DoD) issued a proposed rule last week that would modify 32 Code of Federal Regulations (CFR) Part 97, DoD's "Touhy regulation."
    United StatesGovernment, Public Sector
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Trade Compliance Flash: Forced Labor In Supply Chains: CBP's Latest Ruling Provides Insight Into CBP Scrutiny Of Third-Party Audit Reports

    A recent ruling issued by U.S. Customs and Border Protection provides helpful insight into CBP's review of third-party audit reports in deciding whether to release goods that have been detained on grounds of suspected forced labor.
    United StatesInternational Law
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered

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