Michael J. Wilder
By Elizabeth C. Lu, Caroline H. Ngo, Michael J. Wilder and Lowell D. Yoder 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...
By Jonathan D. Lockhart, Lowell D. Yoder, Michael J. Wilder and Timothy S. Shuman on Sep 13, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
Following the 2017 Tax Act, the US tax costs to a corporate US shareholder that sells stock in a controlled foreign corporation (CFC) are significantly reduced. Beginning in 2018, the amount of gain will be generally less than in prior years and most or all such gain will frequently not be subject to any US...
By Kristen E. Hazel, Michael J. Wilder and Michael F. Kelleher on Dec 7, 2017
Posted In Tax Reform, Uncategorized
A number of provisions included in the Senate’s tax reform bill, H.R. 1 (the Senate Bill) would impact the insurance sector. Many of the provisions would affect only the life insurance industry. Others affect property & casualty (P&C) insurance companies. Still others affect both life and P&C insurance companies. Many of these proposals align with proposals...
By Michael J. Wilder on Jun 30, 2017
Posted In Court Procedure Matters, Uncategorized
In Duquesne Light Holdings, Inc. v. Commissioner, 3d Cir., No. 14-01743 (June 29, 2017), the US Court of Appeals for the Third Circuit upheld a Tax Court decision that disallowed a second deduction for the same economic loss claimed by a consolidated group with respect to stock of a member. The court concluded that the...
By McDermott Will & Emery, Gary C. Karch, Kevin Spencer, Madeline Chiampou Tully, Michael J. Wilder and Robbie H. R. Chen on May 12, 2016
Posted In IRS Audits, IRS Guidance, Uncategorized
We recently released the May 2016 issue of “Focus on Tax Strategies and Developments,” which can be viewed in its entirety here or through the links below. The issue includes four articles of interest to taxpayers: Proposed Debt-Equity Regulations Have Dramatic Implications for Corporate Tax Planning and Compliance By Thomas W. Giegerich and Michael J. Wilder On...