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Proposed Regulations Under Section 965

USA - August 24 2018 On August 9, 2018, the Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS” or the “Service”) published in the Federal…

Thomas R. May, Reza Nader, Julia Skubis Weber

Treasury Issues Temporary and Final Code Section 385 Regulations

USA - November 1 2016 On April 4, 2016, the United States Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) proposed regulations (hereinafter, “Proposed…

Sukbae David Gong, Paula R. Levy, John D. McDonald, Alexandra Minkovich, Steven R. Schneider

Proposed Regulations Under Code Section 385

USA - April 19 2016 The U.S. Department of Treasury ("Treasury") and the IRS recently issued proposed regulations under Code Section 385 (the "Proposed Regulations," and…

Jerred G. Blanchard, Jr., Michael P. Liu, Christine Agnew Sloan

North America tax news and developments - Volume 15, Issue 5

OECD, USA - December 18 2015 In September 2015, the Treasury Department and the IRS issued final regulations providing guidance with respect to transactions that qualify as…

Brad Clements, Lindsey Goble, Thomas (Tom) V. Linguanti, Thomas R. May, Robert S. Walton

North America tax news and developments - volume 15, issue 5

OECD, USA - October 27 2015 On October 5, 2015, the Organisation for Economic Co-operation and Development (“OECD”) issued a final package of measures in the Base Erosion and…

Michael J. Bruno, Alexandra Minkovich, Joshua D Odintz, Kathryn Rimpfel, Sean J. Tevel