Kristen E. Hazel

US Tax Reform Measures Affecting Foreign Multinationals

Grecian Magnesite Mining v. Commissioner: Foreign Investor Not Subject To US Tax On Sale Of Partnership Interest

IRS Identifies Certain 831(b) Captives As "Transactions Of Interest"

The Interplay Between Tax Planning And IP Planning

U.S. Tax Court Upholds Favorable Definition Of Insurance

New Temporary Regulations Narrow The Application Of The Subpart F Active Rents And Royalties Exception

Treasury And IRS Issue New Temporary Treasury Regulations

Treasury Releases Guidance For Contributions Of Appreciated Property To Partnerships With Related Foreign Partners

Distinguishing Between Captive Insurance And Related Party Derivatives: Chief Counsel Advice Memorandum 201511021

IRS Rules Captive Reinsurance Arrangement Involving Retiree Medical Benefits Qualifies As Insurance For Federal Tax Purposes