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U.S. Companies Leading M&A Surge Despite Treasury Action to Limit Transactional Options

USA - March 22 2016 David Forst and Jim Fuller of Fenwick & West summarise numerous developments in the U.S. M&A tax landscape after a record year for dealmaking -...

James P. Fuller.

AM 2015-01does previously taxed income “tier up” to a domestic corporate shareholder?

USA - April 8 2015 In a recent Chief Counsel memorandum (AM 2015-01), the IRS addressed a long uncertain tax question: when a US corporate shareholder includes an...

William R. Skinner.

Commissionnaires and other PE structures under scrutiny as part of BEPS

Global - December 9 2014 The OECD has recently published a discussion draft on the portion of its BEPS action plan dealing with permanent establishments and has titled this...

William R. Skinner.

New chief counsel memorandum revisits definition of “obligation” under IRC 956

USA - October 13 2014 In a recent memorandum, ILM 201436047 (Sept. 8, 2014), the IRS chief counsel seemingly exceeded the scope of its own regulations in advising that the...

William R. Skinner.