William H. Bradley
Eversheds Sutherland (US) LLP
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Proposed Section 892 regulations provide relief from the “all or nothing” rule and permit SWF Limited partners to avoid commercial activity attribution
USA - November 8 2011 Proposed regulations issued under Internal Revenue Code section 892, on November 2, 2011, address some of the most criticized rules under temporary regulations issued more than 20 years ago.
