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Britt Haxton focuses her practice on US and international tax matters for US and non-US multinationals. Britt regularly advises clients on tax-free and taxable acquisitions, dispositions, restructurings and liquidations. In addition, she has experience in providing advice on the Foreign Account Tax Compliance Act (FATCA) compliance and reporting. Britt also advises clients on international tax issues, including foreign tax credit, subpart F and application of bilateral income tax treaties. Read Britt Haxton's full bio.

Proposed BEAT Regulations | Tax-Free Transactions May Give Rise to a Liability


By , and on Dec 20, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized

On December 13, 2018, US Department of the Treasury and the Internal Revenue Service (IRS) released proposed regulations for the Base Erosion and Anti-Abuse Tax (the BEAT), which was added to the Code as part of the 2017 Tax Act. The proposed regulations provide helpful guidance on a range of important topics and generally go...

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Tax Takes Video: Issues Facing CFCs


By , , and on Apr 11, 2018
Posted In Tax Reform, Uncategorized

Partners Alexander Lee, Tim Shuman, Britt Haxton and Jay Singer discuss novel concerns facing CFCs in light of tax reform.

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Deference Provided to Regulations When There’s a Drafting Error


By and on Apr 4, 2018
Posted In Tax Reform, Uncategorized

The Tax Act created two new foreign tax credit limitation baskets – one for foreign branch income (new section 904(d)(1)(B)) and one for any amount includible in gross income under section 951A (i.e., GILTI) – however, it failed to amend section 904(d)(2)(H)(i) to reflect these changes to section 904(d)(1). As a result of this oversight,...

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Base Erosion Minimum Tax May Mean Change for Foreign Affiliates of US Multinationals


By and on Dec 22, 2017
Posted In Tax Reform, Uncategorized

On November 16, 2017, we participated in a panel discussion at Tax Executives Institute’s (TEI’s) Chicago International Tax Forum regarding base erosion measures under the (then proposed) House and Senate tax reform bills. The House proposed a new 20 percent excise tax on most related-party payments (other than interest) that are deductible or includible in...

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The Slow Death of the Section 385 Regulations


By and on Nov 9, 2017
Posted In IRS Guidance, Uncategorized

Internal Revenue Code (Code) Section 385 provides that the US Department of the Treasury (Treasury) is authorized to issue regulations to determine whether an interest in a corporation is to be treated for purposes of the Code as stock or indebtedness. After decades of inaction, proposed regulations were issued on April 14, 2016. The proposed...

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Debt-Equity Regulations – A Year in Review


By on Dec 29, 2016
Posted In IRS Guidance, Uncategorized

Section 385(a) provides that Treasury is authorized to issue regulations to determine whether an interest in a corporation is to be treated for purposes of the Code as stock or indebtedness. On April 4, 2016, Treasury and the Service issued proposed regulations (Proposed Regulations, found here) under section 385 that treat certain purported debt between...

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Final Section 385 Regulations May Pose Compliance Burdens and Raise Potential Challenges


By and on Nov 3, 2016
Posted In IRS Guidance, Privilege and Non-Disclosure, Uncategorized

On November 2, 2016, we participated in a panel discussion at TEI’s Houston Global Tax Symposium regarding the effects of the newly-finalized section 385 regulations. Of interest from a controversy perspective, we discussed the potential compliance burdens and privilege concerns raised by the new documentation requirements in the rules, and the potential problems with the...

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