Jonathan Talansky

Jonathan Talansky

King & Spalding

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IRS and Treasury Issue Proposed Regulations Easing Some of the Burden of the Fractions Rule

Executive Summary On November 22, the Internal Revenue Service (“IRS”) and Treasury Department issued proposed regulations (REG-136978-12, the “Proposed Regulations”) under the “fractions rule” of Section 514(c)(9)(E) of the...more

12/1/2016 - Internal Revenue Code (IRC) IRS Proposed Regulation Taxable Income U.S. Treasury UBTI

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