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Treasury Adds Color to Grecian Repeal - Proposed Regulations Implement New Section 864(c)(8) for Sale of Partnership Interests by Foreign Partners

USA - January 8 2019 On December 20, 2018, the US Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released proposed regulations (the...

Isaac L. Maron, Michael Lebovitz, JoonBeom Pae, James R. Barry, Jared B. Goldberger.


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...

Gary Wilcox, Michael Lebovitz, Lucas Giardelli.


Proposed Regulations Change Calculus of Section 956’s “Deemed Dividend” for US Corporate Shareholders

USA - November 2 2018 On October 31, 2018, the US Internal Revenue Service ("IRS") released proposed regulations ("Proposed Regulations") that, if finalized, may...

Steven D. Garden, David J. Goett.


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, Gary Wilcox, Thomas L. Kittle-Kamp, Brian W. Kittle, Jason M. Osborn, Lucas Giardelli.


Innovation box regime proposed for US Tax Code

USA - July 30 2015 US Congressman Charles W. Boustany Jr. (R-La) and Congressman Richard Neal (D-Mass), both senior members of the Ways and Means Committee, released...

Warren S. Payne, Jason M. Osborn.