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North America Tax News and Developments - September 2018

USA - September 20 2018 On September 13, 2018, Treasury and the IRS released proposed regulations under section 951A. As of the date of this newsletter, the proposed…

Brandon King, Melinda R. Phelan, Michael Farrell, Moiz Shirazi, Paula R. Levy, Robert Hammill, Rodney W. Read.

The Tax Cuts and Jobs Act: Congress Passes A Major Tax Bill For First Time in Thirty Years

OECD, USA - December 20 2017 On December 15, 2017, the conferees working on reconciling the differences between the House and Senate versions of the Tax Cuts...

Daniel W. Hudson, Glenn G. Fox, John D. Barlow, Maria Eberle, Mary C. Bennett, Michael J. Bruno, Paul F. DePasquale, Rod Hunter, Steven Hadjilogiou.

IRS releases proposed regulations on research credit for internal use software

USA - February 20 2015 On January 20, 2015, the Treasury Department and the IRS published long- awaited proposed regulations under Code Section 41 (the “2015 Proposed…

Ian Yuon Siu.

New final and proposed regulations under Code Section 904 explain treatment of overall foreign and domestic losses and related coordination rules

USA - October 31 2012 On June 22, 2012, Treasury Department released new final regulations ("Final Regulations") under Code Section 904.

Kevin T. Bendemire.

International business

USA - March 1 2010 With the inevitable recovery of the global economy, more and more companies are considering expansion into jurisdictions outside the US.

Peter R. Denwood, Susan F. Eandi.