Bernie Pistillo

Russia Exodus Raises Tough Tax Issues For Companies

New Section 956 Regulations Expand Scope Of The New Participation Exemption But May Expose Borrowers To Increased Collateral Requirements

Trump Administration Officials And Congressional Leaders Release "Unified Framework" For Tax Reform

IRS Issues Final Debt-Equity Regulations

Latest Treasury Action On Inversions Upends Pending Transactions And Surprises Many For Its Broad Scope And Use Of Questionable Authority

Proposed IRS Debt-Equity Regulations: Aimed At Post-Inversion "Earnings Stripping," But May Also Impact Ordinary Related-Party Debt

Recent Changes Make Permanent The 100% Exclusion Of Eligible Gain From Sales Of Section 1202 "Qualified Small Business Stock"

Private Ruling Endorses Taxpayer-Friendly Reading Of "Qualified Small Business" Under Section 1202

The Inversion Craze: Will Today's Routine Tax Planning Be Retroactively Outlawed?

Recently Proposed Treasury Regulations Regarding The Allocation Of Partnership Recourse And Nonrecourse Liabilities Contain Significant Changes For Many Routine Partnership Transactions

Managing Offshore Holding Companies From China: Recent Case May Suggest Increased Tax Risk

Favorable New Guidance On Eligibility Of Wind And Other Renewable Energy Facilities For The PTC Or The ITC In Notice 2013-60

Recent Changes Allow Tax-Free Receipt Of Up To $10 Million In Gain From The Sale Of Small Business Stock

A Year-End Rush for the Exit? Tax Uncertainty and Transactional Planning in Q3/Q4 2012

2011 Report Of Foreign Bank And Financial Accounts ("FBAR") Due June 30

Reasserting Its Role As Final Interpreter Of The Law, The Supreme Court Rejects IRS "Fighting Regulation" In United States v. Home Concrete & Supply, LLC, Et Al.