Subpart F and Net CFC Tested Income - Part 1

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Sean advises clients, including early-stage startups, unicorns, and Fortune 100 multinationals on a wide array of domestic and international tax planning and tax controversy matters. Sean has particular expertise advising clients on tax matters related to blockchain and cryptocurrency ecosystems. He has advised numerous clients on tax issues relating to token generation events, private token s

Will Skinner focuses his practice on corporate tax planning and transactions, including mergers and acquisitions, financings, spins, restructurings, partnerships, and licensing matters. Will draws on extensive experience with technology and life sciences transactions to shape tax structures in pursuit of clients’ business goals. Will also provides corporations with standalone tax advice, includin