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IRS untangles section 163(l) in cross-border hybrid financing transaction

USA - May 13 2015 "In terrorem" or anti-abuse provisions often receive a lack of judicial and administrative interpretation. Section 163(l) of the Code, enacted in...

AM 2015-01does previously taxed income “tier up” to a domestic corporate shareholder?

USA - April 8 2015 In a recent Chief Counsel memorandum (AM 2015-01), the IRS addressed a long uncertain tax question: when a US corporate shareholder includes an...

David L.Forst.

Taxation of foreign currency

USA - February 21 2015 This outline provides a plain English summary of the tax provisions of Subpart J of the Code governing the taxation of foreign currency gain or loss...

Commissionnaires and other PE structures under scrutiny as part of BEPS

Global - December 9 2014 The OECD has recently published a discussion draft on the portion of its BEPS action plan dealing with permanent establishments and has titled this...

David L.Forst.

New chief counsel memorandum revisits definition of “obligation” under IRC 956

USA - October 13 2014 In a recent memorandum, ILM 201436047 (Sept. 8, 2014), the IRS chief counsel seemingly exceeded the scope of its own regulations in advising that the...

David L.Forst.