Tax Law News and Insights

Repatriating Untaxed Foreign Earnings Using Section 311(b) Distributions or Section 964(e) Stock Sales Introduction: Pairing Section 311(b) Distributions or Section 964(e) Stock Sales with the Section 245A DRD U.S. multinational corporations may be able to use section 311(b) distributions or section 964(e) stock sales with the section 245A dividends received...

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On September 28, 2022, the OECD published the Bilateral Advance Pricing Arrangement ("BAPA") Manual. The manual proposes best practices for jurisdictions to streamline, expedite and improve BAPA processes based on member surveys. Most notably, the BAPA manual encourages jurisdictions to conclude BAPAs within 30 months and to work to further reduce...

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Crypto industry groups had hoped to use the tax refund case of Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn.) as the vehicle to prove that staking rewards received by a crypto validator only trigger gain upon the ultimate disposition of the reward, rather than constituting taxable income upon receipt. However,...

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