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Miller Canfield

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

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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

Orrick, Herrington & Sutcliffe LLP

New Panel, Same Result – Ninth Circuit Upholds Controversial Cost-Sharing Regulations in Altera Case

Orrick, Herrington & Sutcliffe LLP on

The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more

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