Tag Archives: international tax

Killing the Killer B: The Treasury and IRS Issue a Sixth Set of Rules on Killer B Transactions

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The Treasury looks to slay Killer B transactions with its newest rules. Our International Tax Group follows the trail of glitches in the regulation.

Read the full advisory here.

International Tax Advisory: Through the Looking Glass: Reporting by Foreign-Owned Disregarded Entities

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In the wake of the Panama Papers leak, the IRS and Treasury have announced proposed regulations to require significant reporting by foreign-owned domestic disregarded entities. Our International Tax Group considers the implications of this anticipated regulatory burden.

Federal Tax Advisory: General Utilities Repeal and Spins

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Our Federal Tax Group notes IRS concerns about Section 355 tax-deferred spinoffs, including the relevance of the 1986 repeal of the General Utilities doctrine.

Click here to view the entire advisory on the Alston & Bird website.