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Results: 1-10 of 123

OECD releases first BEPS recommendations to G20 in accordance with Action Plan

  • Jones Day
  • -
  • Global, USA
  • -
  • October 2 2014

As a part of the OECDG20 project to combat base erosion and profit shifting ("BEPS"), the OECD released the first set of reports and recommendations

Treasury Department and IRS issue long-awaited inversion guidance

  • Jones Day
  • -
  • USA
  • -
  • October 2 2014

On September 22, 2014, the U.S. Treasury Department and the IRS issued long-awaited inversion guidance in the form of Notice 2014-52. The Notice sets

IRS issues guidance regarding the deductibility of litigation fees incurred by branded pharmaceutical companies when defending their patents against challenges to market exclusivity by generic companies

  • Jones Day
  • -
  • USA
  • -
  • October 2 2014

There is welcome clarity for branded pharmaceutical companies seeking to deduct legal fees incurred in defending their patents against challenges to

Treasury Department and IRS issue long-awaited inversion guidance

  • Jones Day
  • -
  • USA
  • -
  • September 24 2014

On September 22, 2014, the U.S. Treasury Department and the IRS issued long-awaited inversion guidance in the form of Notice 2014-52. The Notice sets

FATCA recent developments

  • Jones Day
  • -
  • USA
  • -
  • June 3 2014

Implementation of the U.S. FATCA regime proceeds on schedule, with no changes to the effective dates, and none now expected. Thus, withholding will

Global tax update - United States - May 2014

  • Jones Day
  • -
  • USA
  • -
  • May 12 2014

On April 1, the Senate Permanent Subcommittee on Investigations held another hearing on multinational corporations that actively reduce their

Dealing with the Affordable Care Act in labor contract negotiations - Part II: the looming excise (a.k.a., Cadillac) tax

  • Jones Day
  • -
  • USA
  • -
  • November 6 2013

The Affordable Care Act ("ACA") imposes new taxes and fees on employers that will affect bargaining over health benefits. Some of these new costs

Internal Revenue Code Section 336(e) elections: basic overview

  • Jones Day
  • -
  • USA
  • -
  • September 13 2013

The U.S. Treasury Department recently issued final regulations allowing certain taxpayers to make a special election to treat a disposition of

Six-month extension of FATCA deadlinesanother joy of Summer

  • Jones Day
  • -
  • USA
  • -
  • July 15 2013

The IRS announced on Friday, July 12, in Notice 2013-43 (the "Notice") that the earliest deadlines under the Foreign Account Tax Compliance Act

Euroresource--deals and debt

  • Jones Day
  • -
  • Argentina, Germany, Macau, United Kingdom, USA
  • -
  • June 28 2013

On 24 June 2013, the Republic of Argentina filed a petition asking the U.S. Supreme Court to review a ruling handed down by the U.S. Court of Appeals