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Department of Treasury

Regulation Confusion

May 2, 2018 By Jasper L. (Jack) Cummings, Jr.

The Office of Management and Budget may throw a wrench into how IRS and Treasury regulations are treated. Our Federal Tax Group outlines why slowing down the regulation process may be the least of taxpayers’ worries. Will the OMB discard traditional distinctions? Legislative vs. interpretive regulations What does it mean for tax reform? Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: Department of Justice, Department of Treasury, IRS, Office of Management and Budget, OMB, regulations, Tax Court, Treasury

Treasury Would Overhaul 2016 Regulatory Guidance

October 16, 2017 By Edward Tanenbaum and Heather Ripley

With tax reform on the horizon, Treasury takes aim at three sets of regulations with clear cross-border implications. Our International Tax Group explains the department’s recommendations to scrap much of Section 385 and overhaul Sections 367 and 987. Revoking the Section 385 documentation rules Expanding the active business exception to foreign goodwill under Section 367 Deferring transition rules under Section 987 to 2019 Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: business exception to foreign goodwill, deferred transition rules, Department of Treasury, foreign goodwill, Section 367, Section 385, section 987, tax reform, Treasury, Treasury Department

Federal & International Tax ADVISORY: Big Tax Court Win for Foreign Investors in U.S. Partnerships

July 24, 2017 By Edward Tanenbaum, Andy Immerman, Stefanie Kavanagh and Scott Harty

Our Federal & International Tax Group examines the long-awaited decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner. While a win for foreign investors in U.S. partnerships, it may not be the final word. Repudiates decades-long position of IRS May have a real impact on U.S. foreign investment May not be the last word on the subject Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory, International Tax Advisory Tagged With: aggregate, Department of Treasury, entity, foreign investor, Grecian Magnesite Mining, INdustrial & Shipping Co., IRS, Obama Administration, Rev. Rul 91-32, SA, Section 741, Treasury, Trump, v. Commissioner

International Tax ADVISORY: Impact of the Multilateral Instrument of U.S. Taxpayers

July 14, 2017 By Edward Tanenbaum and Stefanie Kavanagh

Nearly 70 countries have signed the OECD’s multilateral instrument – but the U.S. isn’t one of them. Our International Tax Group takes stock of how the MLI will prevent base erosion and profit shifting (BEPS) and what it all means for U.S. companies. What is the multilateral instrument? Why didn’t the U.S. sign it? How will it impact U.S. multinationals? Read the complete advisory here. [...]Read more

Filed Under: International Tax Advisory Tagged With: Action 14 initiative, Action 15, base erosion and profit shifting, BEPS, cross border tax disputes, Department of State, Department of Treasury, international tax, limitations on benefits, mandatory binding arbitration, MLI, model tax treaty provision, multilateral instrument, OECD, PPT, principal purpose test, Senate, Treasury Department

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