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Internal Revenue Code (IRC) Foreign Nationals Internal Revenue Service

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

Miller Canfield on

As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

Wilson Sonsini Goodrich & Rosati

Recent Guidance Regarding Withholding on Certain Transfers of Partnership Interests by Non-U.S. Persons

On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-29, "Guidance Regarding the Implementation of New Section 1446(f) for Partnership Interests That Are Not Publicly...more

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