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BEATen Up (Again): The IRS Issues Proposed Regulations Under the Base Erosion Anti-Abuse Tax

USA - January 22 2019 The BEAT functions as a minimum tax in that it only applies if a taxpayer’s liability under the BEAT (referred to as “Base Erosion minimum tax...

Remmelt Reigersman, Mark H. Leeds, Jason M. Osborn.


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, Kenneth Klein, JoonBeom Pae, James R. Barry, Jared B. Goldberger.


IRS Releases Proposed Anti-Hybrid Regulations

USA - January 2 2019 The US Tax Cuts and JOBS Act of 2017 (“TCJA”) added new Sections 245A(e) and 267A to the Internal Revenue Code of 1986 (the “Code”)...

Warren S. Payne, Thomas A. Humphreys, Brennan W. Young.


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, Gary Wilcox, Lucas Giardelli.