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Internal Revenue Service Foreign Equivalency Determination

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Holland & Knight LLP

U.K., U.S. Reach Competent Authority Agreement on "Equivalent Beneficiary" Status

Holland & Knight LLP on

The United Kingdom and the U.S. Competent Authorities published on July 28, 2021, a Competent Authority Agreement (the Agreement) under the bilateral U.K.-U.S. Income Tax Treaty (the U.K. Treaty). It provides for purposes of...more

Dechert LLP

New Foreign Equivalency Determination Regulations

Dechert LLP on

The IRS released final regulations under Internal Revenue Code Sections 4942 and 4945 on September 25, 2015, specifically addressing grants by private foundations to foreign organizations. These final regulations are partly...more

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