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Today in Tax: IRS Introduces Fast-Track Process for Obtaining Letter Rulings
Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance.
IRS Introduces Fast-Track Process for Obtaining Letter Rulings
Corporate reorganizations and spin-off transactions are transactions where there is often...
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How NCAA Can Avoid Athlete Compensation Antitrust Issues
This article was originally published in Law360.In the past year, laws permitting college athletes to profit off their name, image and likeness, or NIL, have gone into effect in states around the country.The grant of that right to college a...
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Today in Tax: Model Global Minimum Tax Rules and Gain Exclusion for Software Companies
Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance.
Model Rules for a Global Minimum Tax
Companies should start preparing for the implementation of the OECD’s global minimum tax regime. Importantly, while...
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Name/Image/Likeness Coming to Oregon K-12 Soon? Potential Impacts of the OSAA’s NIL Decision and Why Districts Need to Pay Attention Now
The Oregon School Activities Association (OSAA) is set to consider language at its Feb. 7 meeting that could officially open the door to Oregon high school athletes profiting from Name Image Likeness (NIL) activities. An NIL activity is any business...
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Today in Tax: Financial Contract Modification and Foreign Tax Credits
Brief commentary on recent cases, rulings, notices, and related federal tax guidance.
Transition rules allow opportunity to avoid taxable income when modifying financial contracts from IBOR to another metric
Contracts dependent on a discontinued in...
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Today in Tax: Eligibility of Electronic Services Income for FDII Deduction
Brief commentary on recent cases, rulings, notices, and related federal tax guidance.
Regulations open door for cloud computing, streaming, and related electronic services to be included in deduction computation.
In late 2017 the Tax Cuts and Jobs...
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