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Larissa Neumann, Fenwick & West

Larissa Neumann

Fenwick & West

Larissa Neumann's Passles

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The BEAT switch

The BEAT switch

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GILTI and 904 Expense Apportionment

GILTI and 904 Expense Apportionment

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OECD Profit Attribution Report

The original OECD Profit Attribution report relied on the AOA, with an additional conceptual stretch, to move assets and taxable income...

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Foreign Holding Companies

The benefits of using a foreign holding company structure after US tax reform depends on the facts involved.

If a particular holding company’s only purpose was to avoid US tax under the previous rules, for example, to enable a freer flow of cash...…

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