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Michael Rapoport

Michael Rapoport

Senior Reporter at Bloomberg Tax

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Influence score
50
Phone
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Location
United States
Languages
  • English
Covering topics
  • Finance & Banking Services

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Recent Articles

news.bloombergtax.com

Long Commutes, Fear of the Future: What Made IRS Attorneys Quit

Six former Office of Chief Counsel attorneys spoke with Bloomberg Tax about their recent experiences at the IRS and what prompted them to leave the agency—an exodus that’s raised concerns about slowing the progress of cases and curbing tax-enforcement efforts.
news.bloombergtax.com

IRS Clarifies How Global Group’s Entity Treats Lending Income

An entity organized by an international organization that lends to private enterprises in developing countries doesn’t have “effectively connected” income for US tax purposes as the result of holding interests in those loans, the IRS has ruled.
news.bloombergtax.com

IRS Book-Tax Guidance Provides More Leeway for Partnerships

New Treasury Department and IRS guidance will provide much-desired flexibility for partnerships and their partners to determine how much of their income is subject to the corporate book-income tax, practitioners and other observers said.
news.bloombergtax.com

Treasury Revamps Guidance on Book-Income Tax, Partnerships (1)

The Treasury Department and IRS are making a host of changes in how the corporate book-income tax should apply to partnerships and their partners, one of the hottest subjects surrounding the tax.
news.bloombergtax.com

Manufacturers, Telecoms Will Save From Tax Law’s Interest Move

A new, long-sought $60 billion tax break on companies’ interest payments stands to save cable and telecommunications providers like Charter Communications and drug makers like AbbVie millions of dollars a year.
news.bloombergtax.com

IRS Eyes Changes to Proposed Cloud-Computing Rules, Official Says

The IRS may revise its proposed regulations on the sourcing of income from cloud-computing transactions, an agency official said Saturday.
news.bloombergtax.com

Business Advocates Applaud IRS Clawback of Basis-Shifting Plans

Business advocates and advisers welcomed the government’s move to claw back its previous plans to get tougher on a type of transaction that helps complex partnerships. But lots of questions remain about what happens next.
news.bloombergtax.com

Corporate Transparency Act Rules Rollback Issued by Treasury (1)

The Treasury Department issued interim final regulations that limit the companies that must report information about their ownership to foreign reporting companies only.
news.bloombergtax.com

Australia PepsiCo Royalty Case Will Shape Software Tax Approach

Australia’s top court is about to take up a key case involving PepsiCo and royalty taxes, and the outcome promises to shake up the way software makers are taxed, among other industries.
news.bloombergtax.com

Narrowing Partnership Basis-Shift Rules Was Needed, IRS Says

The Treasury and IRS felt it was appropriate to narrow the scope of partnership basis adjustments that must be reported, while still enabling the agencies to identify and tackle potential abuses, an IRS attorney said Tuesday.
news.bloombergtax.com

Australia Debt-Deduction Guidance Seen As Restrictive, Vague

Australia’s recent draft guidance for multinationals seeking interest deductions on their debt is so restrictive and murky that it may end up hurting some of the very companies that authorities are supposed to be helping, critics say.
news.bloombergtax.com

Treasury Aims to Ease Direct Pay for Energy Partnerships (2)

The Treasury Department and IRS on Tuesday finalized rules for electing out of partnership tax status, a move aimed at helping tax-exempt organizations access incentives for clean-energy projects.
news.bloombergtax.com

Americans Abroad Want Relief From IRS on Foreign-Trust Reporting

The IRS’s efforts to revamp its standards on the disclosure of foreign trusts are disappointing to US expatriates, who say the agency hasn’t done enough to clarify whether they’re caught up in the rules.
news.bloombergtax.com

3M Case Offers Test of Chevron Ruling's Sway on Transfer Pricing

A case involving 3M Co. and the IRS may be the first test of how a US Supreme Court ruling giving judges more power to overrule regulatory agencies plays out in the arena of transfer pricing.
news.bloombergtax.com

Lowering Profits Seen as Tactic to Ease New US 15% Corporate Tax

The new alternative minimum tax was designed to hold big profitable companies accountable. But it gives them wiggle room on how they report expenses on their financial statements to investors, and thus an incentive to boost those costs and lower the overall bill. Regulators are weighing that as they prepare to issue long-delayed rules on how the tax should be calculated and applied.
news.bloombergtax.com

High Court's Moore Ruling Sharpens Wealth-Tax Debate (Podcast)

The Supreme Court issued a narrow ruling in its biggest tax case in years, leaving unanswered questions about what the decision could mean for any future wealth tax.
news.bloombergtax.com

Tax Code Chaos Averted in Top Court Ruling but Worry Lingers (1)

The US Supreme Court ruling Thursday on a key foreign-income tax case allays the most dire fears that it could upset other parts of the tax code, but questions remain about what it may signal for a potential future wealth tax and other provisions.
news.bloombergtax.com

Companies Ponder Their Future in Australia After Tax Crackdown - Bl...

Australia’s get-tough stance against multinationals they view as avoiding its taxes could prompt some companies to reassess the future of their businesses there.
news.bloombergtax.com

Grant Thornton Closes Sale of Stake to Private-Equity Firm - Bloomb...

Accounting firm Grant Thornton LLP has completed the sale of a large stake in the firm to private-equity firm New Mountain Capital LLC.
news.bloombergtax.com

IRS Eases Foreign Trust Filing Rules, But Some Want More Relief - B...

A proposed IRS regulation provides needed help in exempting more taxpayers from foreign trust reporting requirements, but practitioners say the agency should go further in providing relief on that and other foreign trust issues.
news.bloombergtax.com

BlackRock’s $821 Million Deduction Spurned by UK Court (1) - Bloomb...

A UK appeals court rejected BlackRock Inc.’s claim that it was entitled to a tax deduction of 654 million pounds ($821 million) on financing for a key acquisition.