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Proposed Anti-Hybrid Regulations under Sections 267A, 245A, and 1503(d)
  • Proskauer Rose LLP
  • USA, OECD
  • January 25 2019

On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid”


The Proposed BEAT Regulations
  • Proskauer Rose LLP
  • USA
  • December 31 2018

On December 13, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the



Sean M. Webb
  • Proskauer Rose LLP