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Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

Latham & Watkins LLP

Multinational Financial Groups After the U.S. Tax Reform: Selected Inbound and Outbound Issues

Latham & Watkins LLP on

Introduction and Overview - The Tax Cuts and Jobs Act (“TCJA”) resulted in the most sweeping changes to the Internal Revenue Code (the “Code”) in decades and will result in countless articles and commentary to address the...more

Orrick, Herrington & Sutcliffe LLP

The Impact of Tax Reform on Private Equity

If the past 12 months have taught us anything, it’s that the future is hard to predict. One need only look at the ascendancy of Brexit, President Donald Trump, or even the New England Patriots in the second half of the Super...more

Latham & Watkins LLP

The Devilish Details of the New Spanish Horizontal Tax Consolidation Regime

Latham & Watkins LLP on

What the new horizontal tax consolidation regime may mean for private equity sponsors, multinational groups, financial institutions (and everyone else…). In June 2014, the European Court of Justice (ECJ) ruled that the...more

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