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
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
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
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
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
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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