Tax Law News and Insights

Key Takeaways The Ohio Supreme Court decision in NASCAR Holdings, Inc. v. McClain is an Ohio commercial activity tax case that provides another recent example of state courts wrestling with how to apply statutory language to source revenue from intangible property. This case could provide persuasive authority for sourcing issues in other...

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On November 10, 2022, US President Joe Biden announced his intent to nominate Danny Werfel to serve as Commissioner of the Internal Revenue Service. US Secretary of the Treasury Janet Yellen has expressed her support for Werfel's nomination. Charles Rettig, whose term expires on November 12, 2022, is the current IRS Commissioner and Doug...

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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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