Obama signs off on American Taxpayer Relief Act of 2012 *

USA - January 4 2013
On January 2, 2013, the President signed into law H.R. 8, the American Taxpayer Relief Act of 2012 (ATRA). Below is a summary of the act, as well as a…

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Tax reform and the fiscal cliff *

USA - December 20 2012
As this newsletter goes to press, the US Congress is in the midst of a lame duck session aimed at coming to a compromise to avert the so-called "fiscal…

Co-authors: Angela J. Walitt.

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The fiscal cliff - tax implications and the Congressional Budget Office's forecast *

USA - October 31 2012
As the country focuses on the presidential debates and general election, lurking around the corner is the lame duck session and a backlog of unfinished business from the 112th Congress.

Co-authors: Thomas S. Respess, III, Jeffrey Tsai, Gene Tien, Melissa Deutsch.

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Treasury releases model intergovernmental agreements, opens new chapter in FATCA implementation *

USA - August 9 2012
On July 26, 2012, the U.S. Treasury Department published two "Model I" intergovernmental agreements (IGAs) which open a new chapter in the U.S. approach to the implementation of the Foreign Account Tax Compliance Act (FATCA), enacted by Congress in 2010.

Co-authors: Mireille R. Zuckerman, Marnin J. Michaels, Peter M. Daub, Mary C. Bennett.

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The codified economic substance doctrine: how we got here, where we are, and where we’re going next *

USA - June 19 2012
This article explores the history of efforts to codify the economic substance doctrine (the “doctrine”), the codification of the doctrine and associated strict liability penalty, and recent Treasury and IRS guidance on how Exam should apply the doctrine and penalty.

Co-authors: Joseph (Jud) B. Judkins, Alisa M. Goodwin.

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