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 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
