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U.S. Treasury Third-Party Internal Revenue Service

Pierce Atwood LLP

Final Regulations on Partnership Recourse Liability Allocation and Related-Party Rules

Pierce Atwood LLP on

Recently, the Treasury Department and IRS released final regulations (89 Fed. Reg. 231) on the allocation of partnership recourse liabilities and related-party rules under Section 752 (the Final Regulations). The Final...more

McDermott Will & Emery

New Temporary Regulations Narrow the Application of the Subpart F Active Rents and Royalties Exception

McDermott Will & Emery on

On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Temporary Regulation § 1.954-2T concluding that third party arrangements cannot be taken into account for...more

Proskauer - Employee Benefits & Executive...

Agencies Issue Final Regulations on the Summary of Benefits and Coverage (SBC) Requirements

As promised in the FAQ issued on March 30, 2015, the U.S. Departments of the Treasury, Labor and Health and Human Services (the Departments) have issued final regulations regarding the summary of benefits and coverage (SBC)...more

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