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Searching Content by David Forst from Fenwick & West LLP ordered by Published Date Descending.
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Treasury And IRS Propose Welcome (And Some Unwelcome) Guidance On The Base Erosion And Anti-Abuse Tax
Treasury and the IRS have issued proposed regulations filling a number of gaps and providing necessary guidance on the Base Erosion and Anti-Abuse Tax (BEAT).
United States
17 Jan 2019
2
The New Foreign Tax Credit Proposed Regulations – An Executive Summary
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts
United States
18 Dec 2018
3
U.S. Companies Leading M&A Surge Despite Treasury Action To Limit Transactional Options
David Forst and Jim Fuller of Fenwick & West summarise numerous developments in the U.S. M&A tax landscape after a record year for dealmaking which puts 2015 on par with 2007 numbers, adjusted for inflation.
United States
30 Mar 2016
4
AM 2015-01—Does Previously Taxed Income "Tier Up" To A Domestic Corporate Shareholder?
In a recent chief counsel memorandum (AM 2015-01), the IRS addressed a long uncertain tax question.
United States
9 Apr 2015
5
Tax Alert: Commissionnaires And Other PE Structures Under Scrutiny As Part Of BEPS
The connective tissue between these two seemingly contradictory statements is a profession by the OECD that all the OECD is trying to do is cure abuse.
United States
12 Dec 2014
6
New Chief Counsel Memorandum Revisits Definition Of "Obligation" Under IRC Section 956
The IRS chief counsel seemingly exceeded the scope of its own regulations in advising that the amount of a CFC’s section 956 investment included accrued but unpaid interest.
United States
15 Oct 2014
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