Author Page: Andrew P. Mitchel — Ruchelman P.L.L.C.

Author Page: Andrew P. Mitchel — Ruchelman P.L.L.C.

articles from insights
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Proposed Regulations on Nondevice & Active Business Requirements Under Code §355

Required Taxable Inclusions from the Loss of §1248 Shareholder Status

Inbound §332 Liquidations & Inbound Asset Reorganization

Outbound Transfers of Stock in Code §351 “Tax-Free” Exchanges

Tax 101: Corporate Reorganizations Part II – Types C, D, E, & F

Tax 101: Corporate Reorganizations Part I – Types A & B

I.R.S. Argues Mylan's Contract is a License of Drug Rights – Not a Sale

Albermarle: Refund Claims Relating to Foreign Tax Credits

I.R.S. Proposed New Partnership Rules Under Code §956

Insights Vol. 2 No. 7: Updates & Other Tidbits

I.R.S. Plan to Reject Foreign Taxpayers' Refunds Criticized by I.R.S. Advisory Committee

Artificial Loan Restructurings

Proposed P.F.I.C. Exception Regulations Detrimental to Foreign Insurers

Eaton Corp.'s Transfer Pricing Trial Begins August 24

“Helen of Troy” Inversions Continue

Competitiveness of the U.S. Tax System

Corporate Matters: Partnerships

Major U.S. Drug Company Avoids Billions in Taxes on $1,000 Pill

I.R.S. Defines Measure for Tax Rate Disparity Test

Nice Work If You Can Get It: A New Yorker's Guide to Change of Domicile

Falciani: "The Man Who Makes the Rich Tremble"

presentations
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U.S. Software Regulations: 20 Years After

Overview of U.S. Taxation of Cross Border Investments & Operations

Anti-Treaty Shopping: Limitation on Benefits Provisions

Roundtable Discussion: Foreign Account Tax Compliance Act (FATCA)

Update on Inversion Transactions & Expatriated Entities