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Final Rules U.S. Treasury Multinationals

Fenwick & West LLP

Key Changes in the Final and Proposed Digital Content and Cloud Computing Regulations

Fenwick & West LLP on

The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

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