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Treasury and the IRS Release Final Foreign Tax Credit Regulations

Final regulations relating to the determination of the foreign tax credit following the Tax Cuts and Jobs Act were released earlier this month. Though largely similar to the proposed regulations, taxpayers may be interested...more

Proposed Foreign Tax Credit Regulations Provide New Rules for Allocation and Apportionment of Deductions and Creditable Foreign...

The Treasury Department and the IRS have issued highly anticipated guidance in the area of stewardship expenses and R&D expenses. The 2019 Proposed Regulations also provide extensive guidance on allocating and apportioning...more

Final and Proposed BEAT Regulations Provide Some Relief

Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more

Interaction of Interest Limitation Rules in the United States and Elsewhere

Until recently, the high US corporate tax rate and regime governing interest deductibility had provided a clear incentive for multinationals (particularly, non-US multinationals) to push interest expense into the United...more

Focus on Tax Strategies & Developments - November 2014

REIT Spin-Offs: Recent Transactions and IRS Rulings - Several recent corporate spin-offs in the United States have involved real estate investment trusts (REITs). Provided several requirements are satisfied, including...more

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