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Articles

University of Washington School of Law

Taxation-Federal

2019

Articles 1 - 4 of 4

Full-Text Articles in Law

Transitioning From Gilti To Fdii? Foreign Branch Income Issues, Jeffery M. Kadet, David L. Koontz Jan 2019

Transitioning From Gilti To Fdii? Foreign Branch Income Issues, Jeffery M. Kadet, David L. Koontz

Articles

In this article, Kadet and Koontz explain the risks and benefits multinationals must consider in deciding whether to transition some operations conducted within a controlled foreign corporation (along with the associated income) into a domestic group member to achieve a structure that qualifies for foreign-derived intangible income.


Letter From Jeffery M. Kadet And David L. Koontz To Internal Revenue Serv. (Aug. 20, 2019) On Notice Of Proposed Rulemaking: Classification Of Cloud Transactions And Transactions Involving Digital Content, Jeffery M. Kadet, David L. Koontz Jan 2019

Letter From Jeffery M. Kadet And David L. Koontz To Internal Revenue Serv. (Aug. 20, 2019) On Notice Of Proposed Rulemaking: Classification Of Cloud Transactions And Transactions Involving Digital Content, Jeffery M. Kadet, David L. Koontz

Articles

No abstract provided.


America's (D)Evolving Childcare Tax Laws, Shannon Weeks Mccormack Jan 2019

America's (D)Evolving Childcare Tax Laws, Shannon Weeks Mccormack

Articles

Proponents have touted the ability of the Tax Cuts and Jobs Act (the TCJA) — enacted in the twilight of 2017 — to help American working families. But while the TCJA expanded some benefits available to parents with dependent children, these parental tax benefits may be claimed regardless of whether or to what extent childcare costs are incurred to work outside the home. To help working parents with these costs (which are often their largest expense), Congress might have turned to two other mechanisms in the tax law — the “child and dependent care credit” and the “dependent care exclusion.” …


Letter From Jeffery M. Kadet To Internal Revenue Serv. (Oct. 6, 2019) On Notice 2019-30, 2019-2020 Priority Guidance Plan - Sourcing Of Cloud Services Income, Jeffery M. Kadet Jan 2019

Letter From Jeffery M. Kadet To Internal Revenue Serv. (Oct. 6, 2019) On Notice 2019-30, 2019-2020 Priority Guidance Plan - Sourcing Of Cloud Services Income, Jeffery M. Kadet

Articles

No abstract provided.