David G. Noren David G. Noren

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David G. Noren focuses his practice on international tax planning for multinational companies. David advises clients on a wide range of "outbound" and "inbound" issues, with a particular focus on the subpart F anti-deferral rules, the application of bilateral income tax treaties, and the treatment of cross-border flows of services and intellectual property rights under transfer pricing and other rules. Read David G. Noren'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 Reform Insight: IRS Slams Door on Refunds/Credits for Taxpayers with Section 965 Transition Tax Liability


By , , and on Aug 21, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized

The Internal Revenue Service (IRS) has issued PMTA 2018-016, reaffirming its position that for taxpayers making an election under Internal Revenue Code (Code) Section 965(h) to pay the transition tax over eight years through installment payments, any overpayments of 2017 tax liabilities cannot be used as credits for 2018 estimated tax payments or refunded, unless...

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Tax Reform Insight: Eligibility Requirements for Reduced Tax Rate on FDII for Royalties


By , and on Jul 18, 2018
Posted In Tax Reform, Uncategorized

A domestic corporation’s royalty income derived in connection with business conducted outside the United States generally is eligible for the reduced 13.125 percent effective tax rate on foreign derived intangible income (FDII). To qualify, the licensee must be a foreign person, and the intangible property must be used outside the US for the ultimate benefit...

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Tax Reform Insight: IRS Doubles Down on Retention of 2017 Overpayments to Satisfy Future Section 965 Installment Payments


By , , and on Jun 19, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized

We previously discussed the Internal Revenue Service’s (IRS) surprising position that for taxpayers making an election under Internal Revenue Code (Code) Section 965(h) to pay the transition tax over 8 years through installment payments, any overpayments of 2017 tax liabilities cannot be used as credits for 2018 estimated tax payments or refunded, unless and until the overpayment...

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IRS Holding 2017 Overpayments to Satisfy Future Section 965 Liabilities


By , , and on May 9, 2018
Posted In IRS Guidance, Uncategorized

In a surprising development, the Internal Revenue Service (IRS) has announced that if a taxpayer’s 2017 payments, including estimated tax payments, exceed its 2017 net income tax liability described under Internal Revenue Code (Code) Section 965(h)(6)(A)(ii) (its net income tax determined without regard to Code Section 965) and the first annual installment (due in 2018)...

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Expansion of Subpart F under the Tax Reform Act


By , and on Feb 8, 2018
Posted In Tax Reform, Uncategorized

Under Subpart F, certain types of income and investments of earnings of a foreign corporation controlled by US shareholders (controlled foreign corporation, or CFC) are deemed distributed to the US shareholders and subject to current taxation. The recent tax reform legislation (Public Law No. 115-97) increased the amount of CFC income currently taxable to US shareholders,...

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The New Base Erosion Minimum Tax


By , and on Jan 19, 2018
Posted In Tax Reform, Uncategorized

The recently enacted 2017 tax reform act imposes a new “base erosion and anti-abuse tax” (BEAT) on large corporations. The BEAT operates as a limited-scope alternative minimum tax, applied by adding back to taxable income certain deductible payments made to related foreign persons. Although positioned as an anti-abuse rule, the BEAT presents challenges for a...

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Tax Reform Conference Committee Reaches Agreement


By , , , and on Dec 18, 2017
Posted In IRS Guidance, Tax Reform, Uncategorized

A House-Senate conference committee has reached agreement on a compromise version of the Tax Cuts and Jobs Act, which includes substantial changes to the corporate and international business taxation rules. The stage now appears to be set for final passage and enactment of the legislation before the end of 2017. Continue Reading.

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Read the October Issue of Focus on Tax Strategies & Developments


By , , , , , , , , , and on Nov 1, 2017
Posted In Court Procedure Matters, IRS Guidance, State Controversy, Tax Reform, Tax Refunds, Transfer Pricing Resource, Trial Courts, Uncategorized

The October 2017 issue of Focus on Tax Strategies & Developments has been published. This issue includes five articles that provide insight into US federal and international tax developments and trends across a range of industries, as well as strategies for navigating these complex issues. Republican Leaders Release Tax Reform Framework By David G. Noren Alexander Lee M&A Tax Aspects...

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Republican Leaders Release Tax Reform Framework


By and on Sep 28, 2017
Posted In IRS Guidance, Tax Reform, Tax Refunds, Uncategorized

The White House and Republican congressional leadership released an outline this week to guide forthcoming legislation on tax reform. This outline will serve as a useful framework in structuring what will be an active, and likely contentious, phase of reform activity. Continue reading.

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