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New Guidance Issued for Transition Tax on Deferred Foreign Earnings

Anti-avoidance rules and limitations on application of the stock attribution rules among the topics to be addressed in forthcoming regulations. Key Points - ..Certain transactions intended to reduce transition tax...more

US Tax Reform: Key Business Impacts, Illustrated With Charts and Transactional Diagrams

Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context. Key Points: ..The legislation alters fundamental aspects of US business taxation...more

Congress Passes Tax Reform Legislation, Implementation Imminent

Final bill retains key aspects of House and Senate proposals with some surprise last-minute modifications. Key Points: ..The bill adopts, with some modifications, earlier US House and Senate tax reform...more

Congressional Tax Reform Proposals: Businesses Will Need to Rethink Key Decisions

Potential legislation would significantly affect businesses across a variety of sectors. Key Points: ..US House and Senate have each passed comprehensive tax reform legislation. ..Proposals would alter fundamental...more

Tax Reform Update: Administration and Congressional Officials Unveil Framework

The proposal would significantly change US taxation of businesses, setting the stage for legislative negotiations, but omits some key details. On September 27, a group of Trump Administration and Congressional leaders...more

Treasury Gives Taxpayers Extra Year to Meet Related-Party Debt Documentation Requirements; Per Se Equity Rule Unchanged

The one-year postponement assists taxpayers that are developing compliance systems, amidst broader government review of the related-party debt regulations. On July 28, 2017, the US Department of the Treasury (Treasury) and...more

Tax Reform Update: 4 Issues to Watch as Congress Nears Summer Recess

Administration and Congressional tax negotiators abandon border adjustment tax, but leave unanswered questions regarding rates, revenues, and taxation of US multinationals. As Congress heads toward its late summer 2017...more

US Tax Reform: Strategies for Executing Transactions in the Face of Uncertainty

Tax reform plans would fundamentally alter the landscape for key business decisions, impacting a business’ legal, finance, corporate development and other divisions, as well as tax groups. Key Points: ..Tax reform...more

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