For decades now, corporate inversions have been the topic of an ongoing debate between legislators, practitioners, and academics. Since the first inversion in 1982, while often arguing on the right methods, policy, and ways, Congress, the U.S. Department of the Treasury (“Treasury”), and...

This paper explores the overlap between Code Section 351 and Code Section 368(a)(1)(B) when there is a transfer of stock in one corporation for stock in another corporation, detailing the distinction between the two in basis calculations. If Section 351 is deemed to be controlling, the basis in...

The Trump Administration, along with the House Ways and Means Committee and the Senate Finance Committee, issued a “Unified Framework” for tax reform on September 27, 2017. This framework is full of paradoxes and inconsistencies that are very hard to simply explain by saying that the...

With promises of “Make America Great Again” and tax reform for “middle-class” Americans, the current federal government administration has implied that the average American would become more prosperous under this tax system. It is no surprise that most middle-class Americans view a...

One central focus of the TCJA was to encourage U.S. international firms to "bring back earnings to the U.S." In an attempt to achieve this goal, the legislation enacted Section 245A, which provides a 100% DRD to U.S. corporations for certain foreign-sourced distributions. Section 304 requires...

With increased technology and access to information, corporations have evolved in order to reflect the concept of corporate social responsibility (CSR) in their global business strategies. Some companies, such as Starbucks Corporation, have taken this concept a step further and chose to...

This paper will be focused on the evolution of the corporate tax world and how Corporate Social Responsibility (CSR) may affect the tax planning of multinational companies. An analysis of the history of reform to the United States tax system will be done starting with its inception in the early...