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  • Article

    TAX TAKE: Wishful Thinking: How A Year-End Tax Package Could Happen

    Now that the House of Representatives has a Speaker and the end of 2023 is fast approaching, eyes are again turning to the potential for a year-end tax package.
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    TAX TAKE: Step By Step: International Tax Developments Continue As The House Stagnates

    While the Speaker drama unfolds and we find ourselves in the middle of the third week of a paralyzed House, Tax Take turns its attention to some noteworthy international tax developments.
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Lessons For Exporters From DDTC's ITAR Consent Agreement With Keysight Technologies

    On August 9, 2021, the U.S. Department of State, Directorate of Defense Trade Controls (DDTC), announced a new consent agreement with Keysight Technologies, Inc.
    United StatesInternational Law
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    IRS Certified PEO Program Leaves Unresolved Qualified Plan And ACA Issues

    The IRS recently implemented the voluntary certification program for professional employer organizations (PEOs) (discussed in a separate blog post).
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    The ERISA Edit: District Court Roundup

    his week, the U.S. District Court for the Eastern District of Kentucky has added to the tangle of decisions addressing the enforceability of individual arbitration clauses in plan documents and employment agreements.
    United StatesEmployment and HR
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    IRS Ramping Up Its Enforcement Efforts, Particularly Of Large Partnerships

    As we previously reported, the IRS issued its long-awaited Strategic Operating Plan this past April for implementing the billions of dollars in additional funding provided by the Inflation Reduction Act...
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    IRS Clarifies Several Issues Related To Section 6055 Reporting In Proposed Regulations

    Ultimately, the proposed regulations are helpful but continue to overlook some areas where further binding guidance in regulations would be helpful.
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    The Making Of "Made In America": White House Begins To Implement New "Buy American" Policies

    The White House recently issued a memorandum, titled "Increasing Opportunities for Domestic Sourcing and Reducing the Need for Waivers from Made in America Laws," which provides guidance to federal agencies on the...
    United StatesGovernment, Public Sector
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Trade Compliance Flash: First Court Challenge To CBP Enforcement Of Withhold Release Order

    In April, an importer filed a first-of-its-kind legal challenge to U.S. Customs and Border Protection's (CBP) enforcement of U.S. law prohibiting the importation of goods produced using forced labor.
    United StatesInternational Law
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Outcome Uncertain After Federal Circuit Oral Argument In Wells Fargo Interest Netting Case

    The Federal Circuit heard argument on November 5 in the government's appeal in Wells Fargo.
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Limits In US-Taiwan Tax Relief Bill Differ From A Typical Treaty

    The United States-Taiwan Expedited Double-Tax Relief Act, which is advancing to the full Senate, would provide an array of tax benefits on certain income earned by qualified residents of Taiwan from US investments or activities.
    GlobalTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Trade Compliance Flash: Takeaways From The Hoshine WRO FAQs

    In June, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) on silica-based products produced by Hoshine Silicon Industry Co. Ltd. (Hoshine) and its subsidiaries.
    United StatesInternational Law
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    IRS Implements New Voluntary Certification Program For PEOs

    Through a flurry of guidance this summer, the IRS has finally implemented the long-anticipated voluntary certification program for professional employer organizations (PEOs).
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Corporate Compliance Considerations Following The Publication Of The Engel List

    by Alejandra Montenegro Almonte, William Barry and Maria Lapetina
    United StatesCorporate/Commercial Law
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    The ERISA Edit: More Coverage Mandates And TiC Enforcement Ahead

    The Departments of the Treasury, Labor, and Health and Human Services (collectively, the Departments) issued a Request for Information (RFI) on Friday seeking public comments on application...
    United StatesEmployment and HR
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Out With The Old: Buy American Act Regulations Set For Major Overhaul

    The Federal Acquisition Regulation (FAR) Council published a proposed rule on July 30, 2021 to overhaul the regulations implementing the Buy American Act (BAA) in federal procurements.
    United StatesGovernment, Public Sector
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Economic Substance Doctrine Applies To Fuel Credits And Variance Doctrine Prohibits Challenge To Penalty Assessment

    In Chemoil Corp. v. United States, the court applied the economic substance doctrine to conclude that the taxpayer was not entitled to the alcohol fuel mixture credit under section 6426(b).
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Guidance From Attachment C: Recent Resolutions Include DOJ Updates To The Requirements For An Effective Compliance Program

    Continuing with recent policy updates (and with more analysis to come on today's M&A policy announcement), the U.S. Department of Justice (DOJ)...
    United StatesCorporate/Commercial Law
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    Treasury Offers Additional Interim Guidance On The Corporate Alternative Minimum Tax

    On September 12, Treasury and the IRS released additional preliminary guidance on the CAMT. Among other items, Notice 2023-64 addresses rules for determining applicable financial statements (AFS)...
    United StatesTax
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered
  • Article

    The ERISA Edit: ICYMI – Court Allows Gender-Affirming Care Ban; DOL Advisory Opinion

    Earlier this year, the legislatures of Tennessee and Kentucky banned certain medical treatments for minors with gender dysphoria, which has been characterized by the American Psychiatric Association...
    United StatesEmployment and HR
    Miller & Chevalier Chartered
    Miller & Chevalier Chartered

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