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IRS proposes regulations that would liberally apply exemption from FIRPTA to qualified foreign pension funds

USA - June 7 2019 The IRS recently released long-awaited proposed regulations to implement an exemption from U.S. federal taxes on the disposition of interests in U.S...

Gregg M. Benson, Peter A. Glicklich.

IRS Proposes New Rules for Withholding on Interest Transfers in Certain Partnerships

USA - May 13 2019 The landmark U.S. tax reform legislation that was enacted at the end of 2017 contained a new federal income tax on gain realized by a foreign seller...

Gregg M. Benson, Peter A. Glicklich.

U.S. Proposed Regulations Target Hybrid Structures and Instruments Retroactively

USA - January 3 2019 The Internal Revenue Service (IRS) and Treasury Department released sweeping proposed regulations on December 20, 2018 implementing two provisions...

Gregg M. Benson, Peter A. Glicklich.

IRS Proposes Regulations Under the Base Erosion and Anti-Abuse Tax

USA - December 18 2018 The Tax Cuts and JOBS Act replaced the U.S. federal corporate alternative minimum tax with the Base Erosion and anti-abuse tax (BEAT), which targets...

Peter A. Glicklich.

Proposed Regulations Would Implement U.S. Interest Stripping Rules After Tax Reform

USA - November 29 2018 As we have noted previously, the Tax Cuts and Jobs Act dramatically changed the limitation on the deductibility of interest expense under section...

Gregg M. Benson, Peter A. Glicklich.