Elizabeth C. Lu

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Elizabeth C. Lu focuses her practice on US and international tax matters. She advises clients on international tax issues, including the subpart F anti-deferral rules, foreign tax credit planning, repatriation, and the international provisions of the Tax Cuts and Jobs Act (GILTI, FDII, BEAT, etc.). Elizabeth has experience advising multinational corporations on global supply chain restructurings, acquisitions, dispositions, joint ventures, post-acquisition integrations, internal reorganizations, tax controversies, and intellectual property migrations. Elizabeth also advises clients on tax treaties, cost sharing agreements, and the taxation of the digital economy. Read Elizabeth Lu's full bio.

Whirlpool Update: New Filings and Distribution for Supreme Court Conference


By , , , and on Nov 4, 2022
Posted In Appellate Courts, Court Procedure Matters, Trial Courts

On November 2, 2022, the Supreme Court of the United States announced that the case of Whirlpool Financial Corp., et al., Petitioners v. Commissioner of Internal Revenue, No. 22-9, has been distributed for consideration at its upcoming conference on November 18, 2022. Meaning, we should have an answer in the next few weeks as to...

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IRS Releases Memorandum Regarding Advance Payments of Section 367(d) Inclusions


By , , and on Oct 19, 2022
Posted In IRS Guidance

On September 23, 2022, the Internal Revenue Service (IRS) released a memorandum (AM 2022-003) concluding that taxpayers cannot make advance payments of section 367(d) inclusions except in the limited situation in which the US transferor receives boot in connection with the initial transfer of intangible property (IP) to a foreign corporation. The memorandum is relevant...

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