McDermott Will & Emery
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By McDermott Will & Emery on Jan 3, 2018
Posted In Tax Reform, Transfer Pricing Resource, Uncategorized
Multinational Enterprises (MNEs) are facing an evolving international tax landscape with long-term implications for tax compliance, planning and controversy. Understanding these changes requires continual effort. Tax Executives Institute recently invited us to explore Country-by-Country (CbC) reporting issues at the 2017 Global Tax Symposium in Houston, Texas. We had a lively discussion and know this will...
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Tax Takes Video: Changes to Interest Deduction
By McDermott Will & Emery and John T. Lutz on Dec 19, 2017
Posted In Tax Reform, Uncategorized
The Senate and House bills include provisions that place limitations on interest deductions for corporations. McDermott Tax partners Alexander Lee and John Lutz discuss several implications for US and US-based multinational corporations, including companies that will be adversely affected by the changes, debt limitations and tax efficiencies of offshore debt, and the changes in lending...
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Tax Reform Conference Committee Reaches Agreement
By McDermott Will & Emery, David G. Noren, Lowell D. Yoder, Sandra P. McGill and Timothy S. Shuman on Dec 18, 2017
Posted In IRS Guidance, Tax Reform, Uncategorized
A House-Senate conference committee has reached agreement on a compromise version of the Tax Cuts and Jobs Act, which includes substantial changes to the corporate and international business taxation rules. The stage now appears to be set for final passage and enactment of the legislation before the end of 2017. Continue Reading.
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Maintaining Confidentiality While Navigating Cross-Border Transactions
By McDermott Will & Emery and McDermott Will & Emery on Dec 14, 2017
Posted In IRS Audits, IRS Guidance, Privilege and Non-Disclosure, Uncategorized
Today, taxing authorities across the globe, including the Internal Revenue Service (IRS), are increasing their efforts to gather and share sensitive taxpayer information, often aggressively seeking copies of tax advice, opinions and analysis prepared by counsel and other advisors. In some situations, tax advisors specifically draft their advice to be shared with third parties, but...
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Governments are Pulling Back the Crypto-Currency Curtain
By McDermott Will & Emery and Roger J. Jones on Dec 13, 2017
Posted In Court Procedure Matters, IRS Audits, IRS Guidance, Trial Courts, Uncategorized
Coinbase Inc., a virtual currency exchange platform, was recently ordered by the United States District Court for the Northern District of California to provide the Internal Revenue Service (IRS) with 2013-2015 transaction data for thousands of Coinbase accounts. See United States v. Coinbase Inc., et al., No. 17-CV-01431-JSC, 2017 WL 5890052, (N.D. Cal. Nov. 28,...
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International News III 2017 | Brexit & the US Administration
By McDermott Will & Emery on Dec 8, 2017
Posted In Uncategorized
McDermott Will & Emery recently published Issue 3, 2017 of International News, which covers a range of legal developments of interest to those operating internationally. This issue focuses on the upcoming Brexit from the European Union and the changes in the US Administration; both subjects which have dominated headlines over the past year. This issue explores...
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A 360-Degree View: November and December 2017
By McDermott Will & Emery on Dec 6, 2017
Posted In Uncategorized
Wrapping Up November – and Looking Forward to December Please view all of the topics we discussed over the last month, and take a look at the upcoming tax controversy events where our lawyers will be speaking in December. Upcoming Tax Controversy Activities in December: December 14, 2017: Catherine Battin, Britt Haxton, Kristen Hazel, Mary...
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Manafort Indictment Is a Good Reminder of FBAR Disclosure Requirements
By Kevin Spencer, McDermott Will & Emery, Roger J. Jones and McDermott Will & Emery on Nov 2, 2017
Posted In IRS Guidance, Uncategorized
On October 30, 2017, Paul Manafort Jr. was indicted for concealing his interests in several foreign bank accounts, as well as tax evasion and a host of other criminal charges. The indictment reminds us how important it is to follow the strict guidelines of the reporting regime that the Internal Revenue Service (IRS) and the...
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Read the October Issue of Focus on Tax Strategies & Developments
By McDermott Will & Emery, Alejandro Ruiz, David G. Noren, Jean A. Pawlow, Kevin Spencer, Kristen E. Hazel, Robin L. Greenhouse, Sandra P. McGill and Timothy S. Shuman on Nov 1, 2017
Posted In Court Procedure Matters, IRS Guidance, State Controversy, Tax Reform, Tax Refunds, Transfer Pricing Resource, Trial Courts, Uncategorized
The October 2017 issue of Focus on Tax Strategies & Developments has been published. This issue includes five articles that provide insight into US federal and international tax developments and trends across a range of industries, as well as strategies for navigating these complex issues. Republican Leaders Release Tax Reform Framework By David G. Noren Alexander Lee M&A Tax Aspects...
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Inaugural Seattle Tax in the City® | Highlights and Takeaways
By McDermott Will & Emery on Oct 23, 2017
Posted In Uncategorized
McDermott extended its popular Tax in the City® program to Seattle, with a meeting on October 12 at the Amazon headquarters. McDermott established Tax in the City® in 2014 as a discussion and networking group for women in tax aimed to foster collaboration and mentorship, and to facilitate in-person connections and roundtable events around the...
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