After a cross-border merger or acquisition, related affiliates often integrate and use the acquired intangibles, such as new ...

Practitioners must observe and protect time limits for requesting a refund, administrative appeals, and litigation.

Acquaintance with relevant Internal Revenue Manual provisions can aid practitioners in protecting clients’ rights in tax ...

Even though recent changes substantially reduced abuse concerns, U.S. corporate shareholders must still comply with the extraordinary reduction rules when deducting certain foreign dividends.

Thresholds and ceilings for individual and corporate deductions under the law known as the One Big Beautiful Bill Act may ...

Hyatt appealed the Tax Court’s decision to the Seventh Circuit. On appeal, Hyatt renewed its arguments that the payments into ...

Focusing on private-equity acquisitions, this article compares merger forms and highlights tax considerations, particularly ...

Foreign companies can realize benefits from establishing domicile in the United States if they observe structural and special ...

Tax Court disallows part of a taxpayer’s Sec. 245A dividends-received deduction and holds post–Sec. 965(c) amount must be ...

Taxpayers issuing related-party loans should assess the consequences if those debt instruments are determined to have a zero ...

The tax profession is standing at a critical inflection point. With sweeping changes on the horizon, including major new tax legislation, evolving IRS priorities, emerging technology such as ...

This annual update covers recent developments, including court cases and selected administrative changes occurring in the 12 months ending March 2026. After a cross-border merger or acquisition, ...