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Updated Interest Deductibility Guidance Released by the IRS under Section 163(j)

USA - August 28 2020 On July 28, 2020, the Treasury Department and the IRS issued final and proposed regulations (the "Final Regulations" and "New Proposed Regulations")…

Brian Harris, Hudson Todd, Kat Saunders Gregor, Leo P. Arnaboldi III, Lucas Caruso.

Proposed Regulations Remove Tax Obstacles to Secure U.S. Domestic Corporate Borrowings

USA - November 6 2018 On October 31, 2018 the Treasury Department released proposed regulations under section 956 of the Internal Revenue Code of 1986, as amended, that…

David H. Saltzman, Elaine B. Murphy.