US inbound update: Reorganization ruling has international ramifications

November 21 2004

Revenue Ruling 2004-83 holds that the sale of one subsidiary to another subsidiary followed by the liquidation of the purchased subsidiary as part of an integrated plan qualifies as a reorganization under Internal Revenue Code (IRC) section 368(a)(1)(D) and is not subject to IRC section 304, whether or not the subsidiaries are part of a consolidated group

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Direct Tax

This week in tax: EU nations drop US pillar two carve-out objections

The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team

Sam Sholli, December 19 2025

Direct Tax

Hogan Lovells, Cadwalader to merge in ‘largest combination in history’

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Noemi Distefano, December 18 2025

Direct Tax

Whose tax is it anyway – Libya’s permanent establishment conundrum

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Salaheddin El Busefi , December 18 2025

Indirect Tax

HMRC scores Supreme Court VAT victory over Hotel La Tour

Hotel La Tour had argued that VAT should be recoverable as a result of proceeds being used for a taxable business activity

Sam Sholli, December 17 2025

Direct Tax

EY recruits provided AI training but still taught ‘old way’

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Sam Sholli, December 17 2025

Direct Tax

KPMG reports 7.5% tax and legal services revenue increase

AI and assisting clients with navigating global tax reform contributed to the uptick in turnover, the firm said

Sam Sholli, December 16 2025

Direct Tax

US Treasury secretary eyes pillar two deal finalisation this week

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Tom Baker, December 16 2025

Direct Tax

Winston & Strawn and Taylor Wessing merger confirmed, new brand unveiled

A new transatlantic firm under the name of Winston Taylor is expected to go live in May 2026 with more than 1,400 lawyers and 20 offices

Noemi Distefano, December 15 2025

Direct Tax

Italy’s opaque tax system underlies in-house discontent, advisers say

As ITR’s exclusive data uncovers in-house dissatisfaction with case management, advisers cite Italy’s arcane tax rules

Tom Baker, December 15 2025

Direct Tax

A taxing week: HMRC’s GfC13 puts tax advisers in an unwinnable situation

The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations

Tom Baker, December 12 2025