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Corporate Taxes Foreign Entities Internal Revenue Service

Eversheds Sutherland (US) LLP

Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)

The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more

McDermott Will & Emery

IRS Announces More LB&I Campaigns!

McDermott Will & Emery on

The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage... The most recent set of campaigns were announced on April 16, 2019,...more

Morgan Lewis

Treasury and IRS Release Notice 2015-54: Potential Impact on Domestic and Foreign Partnerships

Morgan Lewis on

The principal effect of the rules would be to turn virtually any contribution of appreciated property by a US person to a section 721(c) partnership into a taxable gain recognition event. On August 6, the US Treasury...more

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