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The Proposed BEAT Regulations

USA - December 31 2018 On December 13, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the...

David S. Miller, Sean M. Webb, Amanda H Nussbaum, Martin T Hamilton, Michael Fernhoff.


IRS Issues Taxpayer Advisory on Prepayment of 2018 Property Taxes

USA - December 28 2017 The IRS announced yesterday, in IR 2017-210 (the “Advisory”), that state property taxes must be “assessed” in 2017 in order for such taxes to be...

David S. Miller, Martin T Hamilton.


Tax Planning is Crucial to Achieve Potential Spin-Off Benefits

USA - October 11 2017 Today, the Wall Street Journal considers again, on its front page above the fold, the potential benefits of corporate spin-off transactions...

Anne Kim, Martin T Hamilton.


BEPS: OECD Releases Multilateral Tax Treaty Convention

USA, OECD, Global - December 6 2016 The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”) was released by...

Katie Semanski, Martin T Hamilton, Robert E.Gaut.


IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

USA - October 26 2016 On October 13, 2016, the Treasury Department ("Treasury") and the Internal Revenue Service (the "IRS") issued final and temporary...

Anne Kim, David S. Miller, Amanda H Nussbaum, Alan P Parnes, Richard M Corn.