IRS Issues Proposed Regulations on Section 951(a)(2)(B) Planning

Strategies to Recharacterize Gain with Untaxed Foreign Earnings

Whirlpool Petition for Cert

Withdrawal of 2006 Proposed PTEP Regulations

How are stock purchases treated for tax purposes under 26 USC 338? An IRS Letter Ruling on asset acquisitions.

Ninth Circuit Rejects Constitutional Challenges to Section 965 Tax

Flume II: The Tax Court’s Recent Decision Involves UBS of Switzerland and Controlled Foreign Corporations

U.S. Shareholder: Changes Under the TCJA

Advising International Business Ventures: Controlled Foreign Corporations and Subpart F

Advising International Business Ventures: Tax Reform and a Quasi-Territorial Tax System