Reviewing a Foreign Legal Structure
By Andrew Mirisis
Jan 24, 2023
IRS Issues Proposed Regulations on Section 951(a)(2)(B) Planning
By Andrew Mirisis
Dec 19, 2022
Strategies to Recharacterize Gain with Untaxed Foreign Earnings
By Andrew Mirisis
Nov 02, 2022
Whirlpool Petition for Cert
By Gregory Mitchell
Oct 27, 2022
Withdrawal of 2006 Proposed PTEP Regulations
By Andrew Mirisis
Oct 21, 2022
Section 245A Overview and Requirements
By Andrew Mirisis
Oct 06, 2022
How are stock purchases treated for tax purposes under 26 USC 338? An IRS Letter Ruling on asset acquisitions.
By Stephanie Uribe
Aug 10, 2022
Ninth Circuit Rejects Constitutional Challenges to Section 965 Tax
By TL Fahring
Jul 05, 2022
Flume II: The Tax Court’s Recent Decision Involves UBS of Switzerland and Controlled Foreign Corporations
By Jason B. Freeman
Jun 15, 2020
U.S. Shareholder: Changes Under the TCJA
By Jason B. Freeman
Feb 21, 2019
Advising International Business Ventures: Controlled Foreign Corporations and Subpart F
By Jason B. Freeman
Dec 30, 2018
Advising International Business Ventures: Tax Reform and a Quasi-Territorial Tax System
By Jason B. Freeman
Dec 26, 2018