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Safe Harbors Tax Allocation Agreements

Goulston & Storrs PC

Temporary Regulations Address Allocation of Creditable Foreign Tax Expense

Goulston & Storrs PC on

The IRS published temporary and proposed regulations on allocations of creditable foreign tax expenditures (CFTEs).  The regulations make various technical changes to the existing regulatory safe harbor for allocating CFTEs. ...more

Goulston & Storrs PC

IRS Slams Profits Interests In Lieu of Management Fees and More

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The IRS issued the much anticipated proposed regulations that severely curtail the practice of a fund manager waiving management fees in exchange for a share of future partnership profits. In essence the regulations tighten...more

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