Taxpayers worldwide are facing increased scrutiny of, and new attacks against, longstanding tax structures. US corporate taxpayers are subject to some of the highest tax rates in the world, yet are constantly under threat of IRS audits. State and local governments dealing with growing budget shortfalls are developing creative arguments for increasing the tax burden on businesses located inside and outside of their jurisdictions. In this challenging atmosphere, multinational enterprises, mid-market corporations and closely held companies need effective, sophisticated legal guidance.

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To meet these multi-front challenges, clients need legal counsel with experience, international reach and familiarity with all major national and international regulatory regimes and dispute-resolution forums. With a talented team and depth across our offices, McDermott provides effective, coordinated counsel on US antitrust law, EC competition law, China’s Anti-Monopoly Law and other competition laws worldwide.

Key Contacts

Jane Wells May

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December 2015

November 2015

Income Tax Aspects of Subordination in Acquisitions and Renovations

September/October 2015

September 29, 2015

September 21, 2015

The Italian Digital Tax: Some Brief Reflexions

August 25, 2015

Does §956 Apply to Rev. Proc. 99-32 Deemed Receivables?

August 17, 2015

Equitable Tolling and Tax Refund Suits

August 13, 2015

The Upcoming Implementation Of The Italian Patent Box Regime

August 2015

Recent Developments in Tax Law: European Court of Justice re. Verder Lab ...

August 3, 2015

Addressing Sales Tax Issues in Corporate Acquisitions

July-August, 2015

Structural Changes in Light of BEPS

July 6, 2015

IRS Provides Guidance for Calculating the Subpart F Branch Rule's Tax Rate ...

July 2015

Tax on Tax Credits: U.S. Tax Court Addresses Federal Taxation of ...

June 26, 2015

Tax Management Multistate Tax Report

June 15, 2015

Negotiating a Closing Agreement With a Department of Revenue

June 8, 2015

Wynne, Cloud Computing, and a State's Deference to Another

June 4, 2015

District Of Columbia's Transfer Pricing Enforcement Program and Combined Reporting Regime: Taking ...

May - June 2015

Obama Administration Proposes a 19-Percent Minimum Tax on Foreign Earnings

May 28, 2015

Section 162(m) Final Regulations Clarify Requirements for Exemptions to $1 Million Deduction Limitation

May 15, 2015

The "Base Erosion And Profit Shifting" Action Plan of the OECD

May 2015

Joint Venture Companies (4th Edition)

May 1, 2015

Inside the New York Budget Bill: 2015-2016 Budget Enacted

April 27, 2015

If Congress Doesn't Address Remote Sales Taxation, States Will

April 25, 2015

Tax Aspects in Structuring Management Participation Programs, Especially in PE-Transactions, LBO’s ...

April 13, 2015

How to Halve Your Potential State Tax Burdens

April 10, 2015

Proposed New Subpart F Income Category: ‘Foreign Base Company Digital Income’

April 6, 2015

Expedia: New York and Nationwide Implications

March 20, 2015

De Minimis Threshold for the Infection Due to Trade Income Under Section 15 ...

March 18, 2015

Logic vs. the Statute: When Federal Conformity Makes No Sense

March 13, 2015

Section 956: IRS Treats Foreign Property as U.S. Property

March 2, 2015

REIT Spinoffs: Recent Transactions and IRS Rulings

February 26, 2015

Management Participations, from Employed Manager to Entrepreneur

February 23, 2015

A Legal Guide to Investing in France for Foreign Investors

February 23, 2015

Decoding Combination: What Is a Unitary Business

February, 2015

The Frustrations of Fixtures: The Impact of Real Property/Tangible Personal Property ...

February 20, 2015

Attribution of Real Estate for German Real Estate Transfer Tax Purposes in ...

February 2015

Securing Information from Taxpayers by the IRS (Chapter 4)

January-February, 2015

Cross-Border Hybrid Financing Arrangements (a note from the Editor-in-Chief)

January 19, 2015

Taxation Vexation

January 5, 2015

CFOs Face Liability for Business Taxes

November - December, 2014

Time Limits for Filing Refunds Related to Foreign Tax Credits

November - December, 2014

“Inversion”: A Cross-Border Acquisition Structure

December 2014

Practice of International Tax Law 2014

November - December, 2014

“Inversion”: A Cross-Border Acquisition Structure

December 12, 2014

IRS Challenges Characterization of Distribution as a Return of Basis

December 8, 2014

Texas Comptroller Defies the Laws of Physics

December 4, 2014

Recent Developments in Tax Law: Update On International Group Taxation

December 1, 2014

Lame-Duck Congress Mulls Laws to Ease State Tax Headaches

December 1, 2014

Demystifying the Sales Factor: Conduit Receipts

November / December 2014

Cracking the Code: Taxing Developments in Benefit Compliance

November 24, 2014

Market Sourcing: Increasing the Burden on Taxpayers?

November 10, 2014

The Role of Trade Associations and Coalitions in Forming State Tax Policy

November 7, 2014

Alternative Apportionment: Who Bears the Burden of Proof and What Standard of ...

October 2014

Cross-border Transformations of Companies as a New Option

October 10, 2014

IRS Applies the §956 Indirect Investment Rule to a Partnership Loan

October 7, 2014

Tax Controversy 2015

October 3, 2014

IRS Payroll Tax Audits Highlight Importance of Proper Payroll Tax Reporting

September - October 2014

Recent Transfer Pricing Cases

September 22, 2014

Demystifying the Sales Factor: Foreign Receipts

September 22, 2014

Defending an Equitable Apportionment Case, Redux

September 2014

Tax Controversy 2015