Damon M. Lyon

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Damon M. Lyon focuses his practice on cross-border mergers and acquisitions, global planning and international controversies for multinational companies. He advises clients on a broad range of tax issues, including tax-efficient structuring of acquisitions, dispositions, financings, internal reorganizations and joint ventures. Damon also provides advice concerning multi-jurisdictional business structures, such as intangible holding companies and finance company structures. Read Damon M. Lyon's full bio.

Tax Reform Insight: New Foreign Tax Credit Rules May Warrant Restructuring Foreign Branches

By , and on Jun 27, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized

The 2017 Tax Act added a separate foreign tax credit limitation category, or basket, for income earned in a foreign branch. As a result, certain US groups may be limited in their ability to use foreign income taxes paid or accrued by a foreign branch as a credit against their US federal income tax liability....

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Supreme Court Denies Review in Highly Contested Foreign Tax Credit Case

By and on Apr 19, 2016
Posted In Appellate Courts, Tax Refunds, Trial Courts, Uncategorized

On April 18, 2016, the Supreme Court denied certiorari in the foreign tax credit dispute involving Albemarle Corp.  We have previously written about the case here, here, and here, which involved the timeliness of claims for refund pursuant to Internal Revenue Code (IRC) section 6511(d)(3)(A)’s 10-year limitations period. Generally, a taxpayer must file a claim...

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