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.

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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Is a Business Tax Reform Game Plan Beginning to Take Shape?


By , and on Sep 22, 2017
Posted In Uncategorized

Substantial tax reform is underway and the business community is intently awaiting details of this activity with the aim of positioning themselves to maximize opportunities and minimize any costs or risks that reform may present. How will a cut in the corporate income tax rate, the potential adoption of a “territorial” dividend exemption system or...

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