Changes proposed to US tax reporting rules for “outbound” transfers *

USA - February 11 2013
On January 30, 2013, the US Treasury Department (IRS) proposed amendments to existing gain recognition agreement ("GRA") regulations that apply to US…

Co-authors: John L. Harrington, Rich Williams, Marc Teitelbaum.

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IRS clarifies and tightens new 'anti-inversion' regulations *

USA - June 13 2012
On June 7, 2012, the US Treasury Department (the "IRS") issued new regulations interpreting the US tax rules that apply to "expatriated entities."

Co-authors: John L. Harrington, Marc Teitelbaum.

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Taxpayers challenge state tax assessments based on contingent-fee transfer pricing audits *

USA - April 20 2012
In today's economic environment, it is no secret that many states face significant budget shortfalls.

Co-authors: David M. Hryck, Theodor J. van Stephoudt, John L. Harrington.

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US Treasury issues final bank deposit interest reporting regulations *

USA - April 19 2012
On April 17, 2012, the US Treasury Department released final regulations and a revenue procedure setting forth the requirements for US offices of certain financial institutions to report on the interest earned by nonresident individuals.

Co-authors: Jeffrey H. Koppele, John L. Harrington, Marc Teitelbaum.

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New foreign tax credit regulations issued *

USA - February 15 2012
On February 14, 2012, the US Treasury Department ("IRS") published in the Federal Register regulations dealing with two separate but related foreign tax credit issues.

Co-authors: John L. Harrington, Marc Teitelbaum, Paul J. Housey.

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