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Rouzbeh “Robbie” Alipour focuses his practice on US federal income tax matters, with an emphasis on the taxation of US-based multinationals. Robbie’s areas of experience include planning associated with offshore transactions and investments of US multinationals; structuring cross-border financings, integrations and internal restructurings; taxation of foreign currency under Sections 985–989; constructing infrastructure and tools for corporate treasury departments to manage cash; managing US trade or business or local country permanent establishment issues; and implementing US anti-boycott compliance systems and advising on related technical aspects of Section 999. Prior to joining McDermott, Robbie held various positions at both law firms and in industry. He served as in-house tax counsel for a US electronic commerce and cloud computing company based in Seattle, and for a global advertising and marketing company based in New York.Read Robbie Alipour's full bio.
By Andrew R. Roberson, Kevin Spencer and Robbie Alipour on Jun 29, 2020
Posted In IRS Audits, IRS Guidance, Tax Reform
On May 26, 2020, the Internal Revenue Service (IRS) issued PMTA 2020-08 to provide guidance on the period of limitations for Internal Revenue Code (IRC) section 965, transition tax-related adjustments of partnerships. Typically, pursuant to IRC section 6501, the IRS has three years to assess a tax liability for a tax year. However, IRC section...