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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Indirect Tax

HMRC increases VAT investigations into large and medium-sized businesses

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What Corporates Want 2026 use of technology article header

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Tom Baker, April 17 2026

Direct Tax

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Sam Sholli, April 17 2026

Direct Tax

A&M Tax launches in Ireland with EY, DLA Piper hires

It continues a prolific spree of investment for the firm, after it launched in Indonesia, Thailand, Saudi Arabia and Japan in 2025

Sam Sholli, April 16 2026

Transfer Pricing

‘Taxpayers are thrilled’: local experts hail record-breaking Indian APAs

Booming APA statistics reflect the growing credibility of India’s TP framework and the country’s shift toward a tax certainty approach, ITR has heard

Sam Sholli, April 16 2026

Direct Tax

Hogan Lovells Cadwalader merger approved, debut planned for July

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Noemi Distefano, April 15 2026

Podcasts

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Podcast: Side-by-side or upside down? Analysing the future of pillar two

The latest edition of Taxing Times with ITR covers all the controversy from a dramatic period for the carve-out deal, and also dissects the big four's AI strategies

Tom Baker, April 15 2026

Direct Tax

Rethinking permanent establishment in the GCC after pillar two

Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity

Hany Elnaggar, April 14 2026

Direct Tax