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1. The OECD Doesn't Get GILTI.

2. 'Subpar' F? The Role of Anti-Deferral in a Post-GILTI (and Maybe Pillar Two) World.

3. International Tax Watch: The Arm's Length Principle Comes to Brazil--Does Creditability Come with It?

4. Eaton on Appeal: Advanced Pricing Agreements Are Contracts.

5. Getting into the Weed(s): Representing Marijuana Businesses in Tax Matters.

6. Understanding the Real-World Consequences of Pillar II.

7. How Best to Regard? Reg. s. 1.861-20 and Disregarded Sales of Inventory Property.

8. The Tax Court Misses the Forest for the Trees in TBL Licensing LLC.

9. Code Sec. 7874 Is Harming Start-Ups, Squashing Deals, and Deterring Investment.

10. Three Taxes, Two Pillars, One Credit?

11. Who's Afraid of Code Sec. 280E?

12. Complex Media Simplifies Substance Over Form.

13. Did Anyone Notice the TCJA Made Code Sec. 367(b) Obsolete?

14. Location, Location, Location and Foreign Tax Credits.

15. The Foreign Tax Credit Rules Are Coming into Focus.

16. Foreign Use Under the Final FDII Regulations.

17. New Final and Proposed Regulations Under Code Sec. 163(j) and Their Application to Controlled Foreign Corporations.

18. A Closer Look at the Election Under the Code Sec. 245A Temporary Regulations.

19. Homeward Bound: Repatriating Assets and Activities.

20. Foreign Tax Redeterminations Under Code Sec. 905(c): Timing Is Everything.

21. The Final and Proposed BEAT Regulations: A Favorable Turn.

22. Direct, Indirect, or Barely Connected: Rev. Proc. 2019-40 Provides Limited Relief to U.S. Persons Surprised by CFC Ownership.

23. Allocating Tax Attributes in Cross-Border Spin-Offs.

24. Foreign Use Under the Proposed FDII Regulations.

25. International Tax Watch: The Difference Between Now and Never.

26. Stock-Based Compensation Charge Outs in a Post-Tax Reform World.

27. TCJA: So Many Questions, So Little Time; Law leaves significant open questions for Treasury and the IRS to answer.

28. Foreign Tax Credit Planning: The Potential Benefits of Subpart F Income.

29. GILTI, FDII, and the Future of International IP Planning.

30. International tax in flux: with more changes coming, what's your game plan?

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