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Moore of the Same: “The Constitution does not require Fiscal Calamity…” The Supreme Court’s Scathing Rejection of the Moores’ Constitutional Tax Challenge

Devon Bodoh — Fri, 21 Jun 2024 15:05:15 +0000

On June 20, 2024, the Supreme Court issued its opinion in Moore v. United States, ruling 7-2 that the Tax Cuts and Jobs Act’s (the “TCJA”) mandatory repatriation tax (“MRT”) under Section 965 of the Internal Revenue Code1 does not violate the Direct Tax Clause of the Constitution. Congress enacted the MRT as part of

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Proposed Treasury Regulations Update Tax Standards for Bad Debt Deductions by Regulated Financial Companies

Devon Bodoh — Fri, 05 Jan 2024 13:38:48 +0000

On December 28, 2023, the U.S. Treasury Department (“Treasury“) and the Internal Revenue Service (“IRS“) issued proposed regulations (REG-121010-17) updating the standards for when a debt instrument held by a regulated financial company or a member of a regulated financial company group will be conclusively presumed to be worthless for U.S. federal income tax purposes

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Notice 2024-16: Guidance Allowing for Basis Adjustments to CFC Stock Transferred in Inbound Nonrecognition Transactions

Devon Bodoh — Thu, 04 Jan 2024 15:56:19 +0000

Introduction On December 28, 2023, the Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”) announcing the intent of the Treasury Department (“Treasury”) and the IRS to issue proposed regulations addressing basis consequences under Section 961(c)1 relating to certain inbound liquidations and asset reorganizations (collectively “Inbound Non-recognition Transactions”) whereby a U.S. corporation (the “Domestic Acquiring

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Examining the U.S. – Chile Tax Treaty

Devon Bodoh — Wed, 03 Jan 2024 15:52:54 +0000

Introduction On December 19, 2023, the United States Department of the Treasury announced the entry into force of the tax treaty between the United States and Chile (the “Treaty”). Originally signed by the United States and Chile on February 4, 2010, the Treaty was approved by Chilean government in 2015 and was ratified by the

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2023 Tax Country Comparative Guide — U.S. Tax

Joseph Pari — Mon, 09 Oct 2023 17:47:31 +0000

In this publication, the authors provide an overview of Tax laws and regulations applicable in United States. View the publication here.

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IP Phone Home – IRS Issues New Proposed Rules on the Repatriation of Intangible Property

Devon Bodoh — Thu, 04 May 2023 14:59:56 +0000

Section 367(d) of the Internal Revenue Code (the “Code”) provides rules for outbound transfers of intangible property (e.g., intellectual property) by a U.S. person (a “U.S. transferor”) to a foreign corporation. Under these rules, when a U.S. transferor transfers intangible property to a foreign corporation in an otherwise tax-free exchange under Sections[1] 351 or 361, the U.S. transferor is treated as having sold the intangible property in exchange for annual royalty payments (an “annual inclusion”) over the useful life of the intangible property (or a lump sum payment in the case of a disposition of the intangible property following the initial outbound transfer). The U.S. transferor treats the annual inclusion and lump sum as ordinary income and royalties for purposes of determining source and the foreign tax credit limitation category. Final regulations under Section 367(d) were published on December 16, 2016 (the “367 Regulations”).

2022 Tax Country Comparative Guide – U.S. Tax

Devon Bodoh — Tue, 11 Oct 2022 16:15:09 +0000

In this publication, the authors provide an overview of Tax laws and regulations applicable in United States. View the publication here.

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Inflation Reduction Act of 2022

Devon Bodoh — Wed, 24 Aug 2022 13:59:05 +0000

I. Introduction On August 7, 2022, the U.S. Senate passed legislation (H.R. 5376) that includes significant tax law changes (the Inflation Reduction Act or the Act). The Inflation Reduction Act is a reconciliation bill; all 50 Senate Democrats voted for the legislation and all 50 Senate Republicans voted against it, with Vice President Harris casting

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2021 Tax Country Comparative Guide – U.S. Tax

Devon Bodoh — Tue, 05 Oct 2021 14:03:00 +0000

In this publication, the authors provide an overview of Tax laws and regulations applicable in United States. View the publication here.

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