Susan E. O’Banion Susan E. O’Banion

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Susan E. O’Banion focuses her practice on tax matters. Susan previously worked at a Big Four accounting firm, where she focused on international tax. While in law school, Susan served as comment editor for the Journal of Criminal Law and Criminology. Read Susan O'Banion's full bio. 

Tax Reform Insight: New Foreign Tax Credit Rules May Warrant Restructuring Foreign Branches

By , , and on Jun 27, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized

The 2017 Tax Act added a separate foreign tax credit limitation category, or basket, for income earned in a foreign branch. As a result, certain US groups may be limited in their ability to use foreign income taxes paid or accrued by a foreign branch as a credit against their US federal income tax liability....

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GILTI Rules Particularly Onerous for Non-C Corporation CFC Shareholders

By , , , and on Feb 1, 2018
Posted In Tax Reform, Uncategorized

The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new inclusion rule for non-routine CFC income, termed “global intangible low-taxed income” (GILTI). The GILTI rules apply higher tax rates to GILTI attributed to individuals and trusts who own CFC stock (either directly or through LLCs or S...

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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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Grecian Magnesite Mining v. Commissioner: Foreign Investor Not Subject to US Tax on Sale of Partnership Interest

By , and on Aug 16, 2017
Posted In Court Procedure Matters, IRS Audits, IRS Guidance, Tax Refunds, Trial Courts, Uncategorized

In a long-awaited decision, the US Tax Court recently held that gain realized by a foreign taxpayer on the sale of a partnership engaged in a US trade or business was a sale of a capital asset not subject to US tax, declining to follow Revenue Ruling 91-32. The government has yet to comment regarding...

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