Tax & Accounting Blog

Section 385 Final Regs. Modify Prop. Regs. to “Minimize Burdens” on Taxpayers

Section 385 Final Regs. Modify Prop. Regs. to “Minimize Burdens” on Taxpayers

In 518-page TD 9790 , October 13, 2016, IRS issued final and Temporary Regulations ("final Regulations") under Section 385 that (1) establish threshold documentation requirements that ordinarily must be satisfied so that certain related-party interests in a corporation are treated as indebtedness for federal tax purposes; and (2) treat certain other … Read More

How to Navigate Complex International Tax Issues

How to Navigate Complex International Tax Issues

International tax departments are being hit from all angles with new regulations and complex issues. From Brexit to BEPS, from FATCA to TPP, the most critical issue is navigating the changing nature of global business and the complex implications for operations. Implementing the right technology, challenging the status quo, and building the right team that … Read More

Apple-Ireland EC Tax Ruling Could Shape Corporate Tax Policies

Apple-Ireland EC Tax Ruling Could Shape Corporate Tax Policies

The European Commission (EC) ruling that Ireland provided illegal tax benefits to Apple could cost Apple €13 billion ($14.5 billion) and significantly impact how companies do business in Europe. The ruling also underscores the challenges the EC increasingly faces and predicts how decisions made in Brussels could impact US tax revenues. The EC takes a … Read More