Podcast Analysis: The U.S. Tax Court decision in PPL Corporation & Subsidiaries v. Commissioner

On this edition, Elizabeth Sweigart and Lynn Loden discuss the distinctive aspects of the U.S. Tax Court's recent decision in PPL Corporation & Subsidiaries v. Commissioner and the holding's potential impact on uncertain tax position reporting preparation. Ms. Sweigart and Mr. Loden examine...

Podcast Analysis: The U.S. Tax Court decision in PPL Corporation & Subsidiaries v. Commissioner

On this edition, Elizabeth Sweigart and Lynn Loden discuss the distinctive aspects of the U.S. Tax Court's recent decision in PPL Corporation & Subsidiaries v. Commissioner and the holding's potential impact on uncertain tax position reporting preparation. Ms. Sweigart and Mr. Loden examine...

The Elusive Basis Problem of the Foreign Tax Credit Limitation

As we know, Congress tinkered with the foreign tax credit (FTC) rules in 2010 in a number of ways. One of those changes was to add Section 901(m) (" Denial of foreign tax credit with respect to foreign income not subject to United States taxation by reason of covered asset acquisitions ") to...

Preserving the Deceased Spousal Unused Exclusion Amount for the Surviving Spouse: IRC Section 2010(c) and Notice 2011-82

By Diane L. Mutolo INTRODUCTION: The Tax Relief Unemployment Insurance Reauthorization and Job Creation Act of 2010 amended IRC Section 2010(c) to allow, after December 31, 2010, a surviving spouse to increase his or her applicable exclusion amount by the deceased spouse's unused exclusion amount...

Preserving the Deceased Spousal Unused Exclusion Amount for the Surviving Spouse: IRC Section 2010(c) and Notice 2011-82

By Diane L. Mutolo INTRODUCTION: The Tax Relief Unemployment Insurance Reauthorization and Job Creation Act of 2010 amended IRC Section 2010(c) to allow, after December 31, 2010, a surviving spouse to increase his or her applicable exclusion amount by the deceased spouse's unused exclusion amount...

Practical Tax Considerations for Sovereign Wealth Fund Investments in the U.S.

Introduction ... [ Prop. Treas. Reg. §§ 1.892-4 and 1.892-5 ]... partly supplement and partly replace the current temporary regulations under IRC Section 892 that have been in place since 2002 (and earlier). Importantly, the proposed regulations offer a few planning opportunities for [sovereign...