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Results: 1-6 of 6

A wooly mammoth: IRS issues expansive guidance regarding tangible property costs

  • Baker & McKenzie
  • -
  • USA
  • -
  • February 22 2012

This article is simply about timing

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

  • Baker & McKenzie
  • -
  • 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

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

  • Baker & McKenzie
  • -
  • 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

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

  • Baker & McKenzie
  • -
  • 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

Obama signs off on American Taxpayer Relief Act of 2012

  • Baker & McKenzie
  • -
  • 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

Tax reform and the fiscal cliff

  • Baker & McKenzie
  • -
  • 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