Lori Hellkamp - US Income Tax Treaties and Claiming Treaty-Based Positions

US Income Tax Treaties and Claiming Treaty-Based Positions: Lori recently spoke on a panel discussing tax treaty benefits available to taxpayers and how to claim them. Topics included identifying relevant treaty-based positions, navigating the “limitation on benefits” clauses in US treaties and certain key forms, including 8833, W-8 and 8802. Lori also discussed the interaction of the new foreign tax credit regulations and treaties. 

The full webinar can be accessed here: http://www.lorman.com/training/409683EAU?discount_code=V8357988&p=13389

Lori Hellkamp - Pharma Tax Considerations

 

Pharma Tax Considerations in Strategic M&A, Joint Ventures, Co-Development, and Royalty Sales: This webinar examines the tax aspects of strategic transactions in pharma and biotech, including avoiding tax pitfalls under current and proposed rules; and how global tax trends are affecting the structure and implementation of transactions. 

 

See the full presentation here: https://www.jonesday.com/en/insights/2022/02/webinar-series-crosspractice-issues-in-life-sciences-ma

Lori Hellkamp - New Fast-Track IRS Guidance For Spin-Offs

New Fast-Track IRS Guidance For Spin-Offs And Other Corporate Transactions:

Earlier this year the IRS established a "fast-track processing" pilot program for certain private letter ruling requests under the jurisdiction of the Office of the Associate Chief Counsel (Corporate). Eligible taxpayers that previously could not seek a ruling given time constraints (such as business exigencies) may now be able to utilize the pilot program to obtain a ruling within 12 weeks. In contrast, taxpayers outside of this program often wait in excess of 6 months to receive rulings. The pilot program's significantly quicker processing time is a welcome development. 

 

Read the full article here: https://www.jonesday.com/en/insights/2022/01/new-fasttrack-irs-guidance-for-spinoffs-and-other-corporate-transactions

 

Lori Hellkamp - Inter-Agency Study Of Digital Assets

 

White House Issues Executive Order Calling For Inter-Agency Study Of Digital Assets: In March 2022, President Biden signed a first-of-its-kind executive order addressing the regulation of cryptocurrencies and digital assets in the United States. The Order calls for a "whole-of-government" approach to study the risks and harness the potential benefits of digital asset technologies, and establishes a number of areas of focus for further research and examination by the relevant federal agencies. 

Read the full article here: https://www.jonesday.com/en/insights/2022/03/white-house-issues-executive-order-calling-for-inter_agency-study-of-digital-assets