Fran Randall Partner Richmond, VA (703)652-0249 Related Industries Retail Financial Services Government Contracting Email Fran Randall
Webinar Jan 11, 2023 Pillar Two Mechanics & Impact Assessment This informational webinar will explore how Pillar Two works and how to compute the top-up tax under OECD Model Rules. Watch Archive
Alert Mar 27, 2022 Omnibus Spending Bill Lacking Section 174 Relief On March 11, 2022, Congress passed the Omnibus spending bill (H.R. 2471, the Consolidated Appropriations Act, 2022) which did not include a… Read More
Video Mar 09, 2021 GILTI Retroactive Election In July of last year, final regulations came out pertaining to the global intangible low-taxed income (GILTI) inclusion under Section 951A,… Watch Now
Article Mar 03, 2021 IRS Issues Final Regs for GILTI and Proposed Regs for the Subpart F Income High Tax Exception On July 20, 2020, final regulations (Final Regulations) were released by the United States (U.S.) Department of Treasury (Treasury) related… Read More
Alert Jul 30, 2020 Further Analysis into the Final Regulations for Section163(j) With the issuance of the final regulations on July 27, 2020 regarding the interest limitation requirements under §163(j), we have developed… Read More
Article Jul 21, 2020 Treasury Issues Final Regulations for GILTI and FDII Under Section 250 On July 9, 2020, final regulations (Final Regulations) were released by the U.S. Department of Treasury (Treasury) and the Internal Revenue… Read More