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MOFO quaterly news - taxtalk - November 2014

USA - November 7 2014 In CCA 201434021 (the "CCA"), the taxpayer was a withholding agent paying U.S.-source interest to nonresident aliens. In general, such interest...

Stephen L. Feldman, Remmelt A. Reigersman, Thomas A. Humphreys, David J. Goett, Shiukay Hung.

Recently proposed Treasury regulations regarding the allocation of partnership recourse and nonrecourse liabilities contain significant changes for many routine partnership transactions

USA - February 10 2014 On January 29, 2014, the Internal Revenue Service ("IRS") and the Treasury Department issued proposed regulations1 (the "Proposed Regulations")...

Michelle M. Jewett, Maureen E. Linch, Bernie J. Pistillo, Shiukay Hung.

IRS releases draft FFI Agreement

USA - October 29 2013 On October 29, 2013, the Internal Revenue Service ("IRS") released Notice 2013-69 (the "Notice"), which includes a draft of the long-awaited "FFI...

Remmelt A. Reigersman, Thomas A. Humphreys, David J. Goett.