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Proposed Treasury Regulations Revolutionize Tax Rules Governing Intercompany Financing Transactions

USA - June 28 2016 Recently proposed Treasury regulations, which will likely be finalized this year, promise to alter the tax treatment of a wide range of intercompany...


New regulations address outbound transfers and transfer pricing

USA - September 21 2015 On September 14, 2015, the Internal Revenue Service (the IRS) and Treasury Department proposed new regulations addressing the tax treatment under...

Paul W. Oosterhuis, Nathaniel Carden, Hal Hicks, John M. Breen, B. Chase Wink.


Challenging the IRS anti-inversion notice: a hollow threat

USA - January 28 2015 On September 22, 2014, Treasury and the IRS issued Notice 2014-52, 2014-42 I.R.B. 712 (the Notice), announcing their intention to issue regulations...

David W. Foster, Kate A. Long, Christopher P. Bowers.