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Corporate reorganization

CRS reports on corporate tax base erosion and profit shifting

CRS reports on corporate tax base erosion and profit shifting

A recently released Congressional Research Service (CRS) Report finds that the magnitude of profit shifting—i.e., using tax planning strategies to avoid, delay, or reduce U.S. tax on income earned overseas—may be significant.It notes that American corporations are reported to be engaged in profit shifting with increasing frequency, including some of the most well known companies: […]

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U.S. tax tinkerers miss real engine of inversions

U.S. tax tinkerers miss real engine of inversions

NEW YORK (Reuters) – There’s a bigger picture when it comes to inversions. The Obama administration wants to discourage companies from striking deals to move overseas and reduce their tax bills. America’s levy on offshore profit, however, is a big driver of domicile-driven M&A. It’s a fudge, whereas U.S. companies could use a clear decision […]

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Spin-off to separate two lines of business qualifies as D reorganization

Spin-off to separate two lines of business qualifies as D reorganization

In a private letter ruling (PLR), PLR 201338040, IRS has concluded that a series of proposed transactions to be entered into by a parent corporation and members of its affiliated group, in order to spin off a line of business to a newly formed controlled corporation, will generally qualify for tax-free treatment under Code Sec. […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney