Fran Randall

This informational webinar will explore how Pillar Two works and how to compute the top-up tax under OECD Model Rules.   

On March 11, 2022, Congress passed the Omnibus spending bill (H.R. 2471, the Consolidated Appropriations Act, 2022) which did not include a…

In July of last year, final regulations came out pertaining to the global intangible low-taxed income (GILTI) inclusion under Section 951A,…

On July 20, 2020, final regulations (Final Regulations) were released by the United States (U.S.) Department of Treasury (Treasury) related…

With the issuance of the final regulations on July 27, 2020 regarding the interest limitation requirements under §163(j), we have developed…

On July 9, 2020, final regulations (Final Regulations) were released by the U.S. Department of Treasury (Treasury) and the Internal Revenue…