New Proposed Regs Clarify U.S. Repatriation Tax Elections

Posted on September 27, 2018

On August 1, 2018, the U.S. Treasury released new proposed regulations to implement a key feature of the Tax Cuts…

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Penalty Increased for Failure To Timely File Form 5472

Posted on September 27, 2018

The Tax Cuts and Jobs Act was enacted on December 22, 2017 and made several headline-worthy changes to U.S. federal…

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Tax Changes Spur Foreign Cleantech Companies to Set Up in U.S.

Posted on July 9, 2018

The U.S. energy and corporate market is increasingly opening up to European clean tech companies as they move to a…

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New IRS Compliance: International Focus

Posted on July 1, 2018

The IRS’s Large Business and International Division recently announced six new enforcement campaigns. Periodically, the IRS has attempted to best…

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Enforceability of Wayfair Decision on Foreign Companies Unclear

Posted on June 28, 2018

The treatment of foreign suppliers remains unresolved following the landmark decision in South Dakota v. Wayfair Inc. that abolished the…

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