Cary D. Pugh

Obama Administration Releases Framework for Business Tax Reforms
Armando Gomez,Cary D. Pugh,Jamal Razavian,Sean M. Shimamoto, February 24, 2012
On February 22, 2012, the White House and the Department of the Treasury jointly released “The President’s Framework for Business Tax Reform” (the Framework), which includes ideas for reforming the federal income tax on business income. In support of its proposals, the Framework...

Obama Administration Proposes Significant Tax Changes
Armando Gomez,Cary D. Pugh,Jamal Razavian,Sean M. Shimamoto, February 17, 2012
On February 13, 2012, the Obama administration released its proposed budget for fiscal year 2013, which includes a number of proposals relating to tax incentives for research and investments in renewable energy property, and numerous changes affecting corporate, partnership and international tax....

IRS Issues Field Directive on Economic Substance
Bryon A. Christensen,Armando Gomez,Julia M. Kazaks,Pamela F. Olson,Cary D. Pugh, July 21, 2011
On July 15, 2011, the Internal Revenue Service (the Service) released a directive providing guidance for Service examiners and managers on the application of the codified economic substance doctrine and related penalties (the Directive). Although issued in the form of internal field instructions...