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EU Suggests Possible WTO Challenge to FDII Regime

European Union, USA - June 10 2019 In early May, the EU submitted a letter to the U.S. Treasury Department and the IRS, suggesting that the foreign-derived intangible income (FDII)…

Molly M. Schneider, Friedemann Thomma

Tax Court Rejects Long-Standing IRS Approach to Taxing Gain and Loss on the Disposition of Partnership Interests

USA - July 25 2017 On July 13, 2017, the Tax Court, in a reviewed opinion of the court in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T…

Sung H. Hwang

Tax Reform Update

USA - December 21 2017 Consistent with both the House Bill and Senate Bill, the Act will implement a territorial tax system intended to reduce the scope of income subject…

Rebecca M. (Becca) Chappell, Grace Chung, Krista R. Hartwell, Friedemann Thomma

House Tax Cuts and Jobs Act

USA - November 15 2017 On November 2, 2017, the House Ways and Means Committee (the "House Committee") released the Tax Cuts and Jobs Act (the "Bill"), which proposes the…

Rebecca M. (Becca) Chappell, Grace Chung, Krista R. Hartwell, Friedemann Thomma

Proposed Treasury Regulations Issued for the FDII Deduction

USA - March 11 2019 On March 4, 2019, the IRS released highly anticipated proposed regulations regarding the foreign-derived intangible income (FDII) deduction that was…

Rebecca M. (Becca) Chappell, Molly M. Schneider, Friedemann Thomma