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Following the BEAT: IRS Issues Proposed Regulations on Application of Base Erosion and Anti-Abuse Tax

USA - January 14 2019 Aggregate corporations related by 50 common ownership, including foreign corporations to the extent of their effectively connected...

Jared W. Grimley, Nicholas J. DeNovio, Michael J. Rowe, Jiyeon Lee-Lim.


IRS Issues Proposed Regulations on Business Interest Deduction Limitations

USA - December 19 2018 On November 26, 2018, the Treasury and the Internal Revenue Service (IRS) released proposed...

Gregory T. Hannibal, Samuel R. Weiner, Lea Li, Chris Ohlgart, Seung Hyun Yang, Joseph M. Kronsnoble, Ana G. O’Brien, Diana S. Doyle, Jiyeon Lee-Lim, Y. Bora Bozkurt, Eric Cho.


New Proposed Treasury Regulations May Eliminate Adverse Tax Consequences on Use of Foreign Credit Support for US Corporate Borrowings

USA - November 5 2018 On October 31, 2018, the US Treasury and Internal Revenue Service issued proposed regulations...

Jocelyn F. Noll, Nicholas J. DeNovio, Aaron M. Bernstein, Joseph M. Kronsnoble, Jiyeon Lee-Lim, Y. Bora Bozkurt.


IRS Previews Upcoming Guidance on Interest Deduction Limitation

USA - April 3 2018 The IRS announces certain key aspects of the interest deduction limitation that will be addressed in upcoming Treasury regulations. Key Points:...

Jiyeon Lee-Lim, Y. Bora Bozkurt.


Congress Passes Tax Reform Legislation, Implementation Imminent

USA - December 20 2017 On December 15, 2017, a conference committee composed of members of the US House of Representatives and the US Senate approved a Conference Report...

Laurence J. Stein, Patrick Allan Sharma, Nicholas J. DeNovio, Joseph M. Kronsnoble, Thomas H. Halpern, Jiyeon Lee-Lim.