US Taxation of IP After Tax Reform
The new tax law has had some important changes relating to taxation of IP. Such changes include a new tax on certain global income...
I focus my practice on U.S. tax planning and tax controversy matters, with an emphasis on international tax planning (inbound and outbound) and restructurings, mergers and acquisitions and transfer pricing. I represent clients from a diverse set of industries and geographic areas. I have represented a number of Fortune 500 companies in U.S. federal income tax matters and have successfully represented clients in federal tax controversies at all levels.
The new tax law has had some important changes relating to taxation of IP. Such changes include a new tax on certain global income...
My colleagues and I co-authored a chapter in Taxation of Intellectual Property under Domestic Law, EU Law and Tax Treaties, which is a...
Is a holding company structure still useful after TCJA? It depends on the facts. A holding-company structure might reduce...
The IRS published updated Section 965 FAQ on 4/13/18, which may be relevant for sec. 965 payments due. Sec. 965 payments need to be...
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