Tax Business Organization Alternative Dispute Resolution (ADR)

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Treasury Releases Select Draft Provisions for Next U.S. Model Income Tax Treaty

The Treasury Department announced draft changes for the U.S. Model Income Tax Treaty — the baseline text used by the Treasury Department when it negotiates tax treaties. The current U.S. Model was last updated in 2006. The...more

MoFo Tax Talk - Volume 4, No. 1 - April 2011

In this issue: IRS Reverses its Position on Closing a Forward with Borrowed Stock; Equity Units Exchange Offer; Repurchase Premiums and Consent Fees; Reporting Obligations for Corporate Actions Continued; Withholding on ADR...more

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