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Corporate Taxes Discounts

Eversheds Sutherland (US) LLP

IRS and Treasury issue final regulations on discounting unpaid losses

The Internal Revenue Service (IRS) and the Treasury Department (Treasury) have issued final regulations that address amendments to the rules for discounting unpaid losses pursuant to Section 846 under the Tax Cuts and Jobs...more

Eversheds Sutherland (US) LLP

Section 199 Scrutiny Continues: Chief Counsel Concludes that Merchant Discount Fees Don’t Qualify as Domestic Production Gross...

On October 23, 2017, the Internal Revenue Service Office of Chief Counsel (Chief Counsel) concluded that certain merchant discount fees earned by a parent company in a consolidated group did not constitute domestic production...more

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