Practice Mobile Menu Trigger Overview Experience Team Insights Subscribe to insights May 11, 2016 Client Update Treasury Increases Focus on Offshore Tax Evasion as New Leaks Emerge from the Panama Papers Just before a major development in the Panama Papers document leak, the United States Treasury Department announced a seri... April 11, 2016 Client Update Treasury Issues New Anti-Inversion Guidance On April 4, 2016, the Internal Revenue Service (the “IRS”) and the Treasury Department (“Treasury”) issued (i) fin... April 11, 2016 Client Update Treasury Proposes Overhaul of Intercompany Debt Rules The Internal Revenue Service (the “IRS”) and the Treasury Department (“Treasury”) on April 4, 2016 released propos... October 28, 2015 Client Update Closing Your M&A Deal on a Weekend In case you are wondering – no, this is not about making the closing more festive, or planning for a champagne celebrati... July 1, 2015 Client Update Recent Compensation-Related Tax Developments This spring, the Office of the Chief Counsel of the Internal Revenue Service (IRS) released three Chief Counsel Advice (CC... June 12, 2015 Articles & Books Amazon Branches Out Before clicking ‘buy now’, we are still advised that our internet purchases are ‘sold by Amazon EU S.a.r.L.’. Eagl... April 3, 2015 Client Update IRS Releases Final Regulations Under Section 162(m): Some Relief for Newly Public Companies On March 31, 2015, the Internal Revenue Service published final regulations under Section 162(m) of the Internal Revenue C... January 8, 2015 Client Update IRS Internal Memorandum Concludes Offshore Fund Engaged in Lending and Underwriting Business in the United States On January 2, the Internal Revenue Service (the “IRS”) released a Chief Counsel Advice memorandum (the “CCA”) that... December 11, 2014 Client Update United Kingdom’s “Google Tax” – Government Unveils Draft Rules The UK Government published this week details of a new 25% “diverted profits” tax, which aims to counter cross-border ... September 23, 2014 Client Update Treasury Issues Long-Awaited Anti-Inversion Guidance The Treasury Department and the IRS yesterday released Notice 2014-52 (the “Notice”), which describes regulations that... Load More
May 11, 2016 Client Update Treasury Increases Focus on Offshore Tax Evasion as New Leaks Emerge from the Panama Papers Just before a major development in the Panama Papers document leak, the United States Treasury Department announced a seri...
April 11, 2016 Client Update Treasury Issues New Anti-Inversion Guidance On April 4, 2016, the Internal Revenue Service (the “IRS”) and the Treasury Department (“Treasury”) issued (i) fin...
April 11, 2016 Client Update Treasury Proposes Overhaul of Intercompany Debt Rules The Internal Revenue Service (the “IRS”) and the Treasury Department (“Treasury”) on April 4, 2016 released propos...
October 28, 2015 Client Update Closing Your M&A Deal on a Weekend In case you are wondering – no, this is not about making the closing more festive, or planning for a champagne celebrati...
July 1, 2015 Client Update Recent Compensation-Related Tax Developments This spring, the Office of the Chief Counsel of the Internal Revenue Service (IRS) released three Chief Counsel Advice (CC...
June 12, 2015 Articles & Books Amazon Branches Out Before clicking ‘buy now’, we are still advised that our internet purchases are ‘sold by Amazon EU S.a.r.L.’. Eagl...
April 3, 2015 Client Update IRS Releases Final Regulations Under Section 162(m): Some Relief for Newly Public Companies On March 31, 2015, the Internal Revenue Service published final regulations under Section 162(m) of the Internal Revenue C...
January 8, 2015 Client Update IRS Internal Memorandum Concludes Offshore Fund Engaged in Lending and Underwriting Business in the United States On January 2, the Internal Revenue Service (the “IRS”) released a Chief Counsel Advice memorandum (the “CCA”) that...
December 11, 2014 Client Update United Kingdom’s “Google Tax” – Government Unveils Draft Rules The UK Government published this week details of a new 25% “diverted profits” tax, which aims to counter cross-border ...
September 23, 2014 Client Update Treasury Issues Long-Awaited Anti-Inversion Guidance The Treasury Department and the IRS yesterday released Notice 2014-52 (the “Notice”), which describes regulations that...