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Treasury Releases Proposed Regulations on Foreign Tax Credits under New International Tax Rules

USA - December 18 2018 On November 28, 2018, the US Department of Treasury (“Treasury”) and Internal Revenue Service (“IRS”) released proposed regulations (“Proposed...

Kenneth Klein, Michael Lebovitz, Lucas Giardelli.

High-Level Overview of the Proposed Regulations on Interest Deduction Limitation Rules

USA - November 30 2018 On November 26, 2018, the Department of Treasury and US Internal Revenue Service released proposed regulations that flesh out the new Section 163(j)...

Isaac L. Maron, Steven D. Garden, Minju Kim, Jeffrey M. Bruns, Lucas Giardelli.

The Tax Act Changes the Game for Transfer Pricing

USA - February 5 2018 The “Tax Cuts and JOBS Act” (the “Tax Act”), signed into law by President Donald Trump on December 22, 2017, fundamentally changes the US...

John T. Hildy, C. Cabell Chinnis, Scott M. Stewart, William G. McGarrity, Kenneth Klein, Thomas L. Kittle-Kamp, Brian W. Kittle, Jason M. Osborn, Lucas Giardelli.

How the Tax Cuts and Jobs Act Will Impact Outsourcing

USA - January 9 2018 The "Tax Cuts and Jobs Act" signed December 22, 2017 (the "Tax Act") changes US tax considerations for cross-border services outsourcing and cloud...

Oren P. Margulies, Daniel A. Masur, Brad L. Peterson, Rebecca S. Eisner, Jason M. Osborn.