US: Foreign-controlled CFCs - assessing the regulations for dealing with downward attri... William Skinner and Mike Knobler of Fenwick & West evaluate the final regulations, which had sought to address unintended consequences caused by the earlier repeal of Section 958(b)(4)’s limitation on... By William Skinner & Mike Knobler October 28 2020
Section 163(j): A closer look at inbound financing developments in the US William Skinner and Mike Knobler of Fenwick & West discuss the practical implications for foreign-parented groups from the final §163(j) regulations. By William Skinner & Mike Knobler September 30 2020
US Inbound: Understanding the new BEAT regulations Jim Fuller and David Forst of Fenwick & West explain the most significant provisions from the new regulations on base erosion and anti-abuse tax. By David Forst & Jim Fuller January 21 2020
US Inbound: Treasury and IRS revoke §385 Documentation Regulations and will revise... David Forst and James Fuller of Fenwick & West discuss the recent changes which modify the exisiting Section 385 regulations. By David Forst & Jim Fuller December 17 2019
US inbound: IRS proposes new guidance for cloud transactions The Internal Revenue Service (IRS) has proposed new guidance regarding cloud transactions. By David Forst & Jim Fuller October 15 2019
US inbound: Ninth Circuit issues decision on § 482 in Altera v Commissioner case James Fuller and David Forst of Fenwick & West analyse the Ninth Circuit’s opinion in Altera v Commissioner, in which the majority held that the “commensurate with income” method can... By David Forst & Jim Fuller August 29 2019
US: Sale of a partnership interest: Withholding tax The US Treasury and the Internal Revenue Service (IRS) have proposed withholding tax regulations regarding the Tax Cuts and Jobs Act (TCJA) provisions, addressing sales of interests in partnerships engaged... By David Forst & Jim Fuller July 10 2019
US tax reforms impact on cross-border M&A While US tax reform may not have affected merger and acquisition (M&A) activity explicitly, a change in laws surrounding controlled foreign corporations (CFCs) will see a number of new tax... By Adam Halpern & William Skinner May 31 2019
US Inbound: Altera decision reversal withdrawn The Ninth Circuit reversed, and then withdrew its reversal of, the Tax Court's unanimous 'reviewed by the court' decision in Altera Corp. v. Commissioner, 145 T.C. By David Forst & Jim Fuller October 15 2018
New York State Bar Association report on BEAT Jim Fuller and David Forst examine the New York State Bar Association's latest analysis of the base erosion and anti-abuse tax (BEAT), which was introduced in the US tax reform. By David Forst & Jim Fuller August 24 2018
