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2022 & Beyond: Continued Challenges in the Automotive Supply Chain

While our inboxes are flooded on a daily basis with news about how the pandemic has created supply chain and commodities issues, global organizations must think about more than just near-term issues. Although the pandemic...more

Deductibility of Fines and Penalties: New Guidance Leaves Key Questions Unanswered

Proposed IRS regulations clarify when fines and penalties are deductible but leave important issues unresolved. The U.S. Internal Revenue Service has released proposed regulations clarifying when fines, penalties, and...more

Favorable Net Operating Loss Utilization Rules Could be Eliminated

Proposed regulations, if adopted, would impose substantial restrictions in many cases on a corporation's use of existing net operating losses and similar tax attributes after a substantial change in ownership. On September...more

Proposed Treasury Regulations Permit Foreign Subsidiary Credit Support for U.S. Multinational Financings

The proposed regulations, released October 31, 2018, generally provide tax-free treatment to a U.S. corporate parent of a controlled foreign corporate subsidiary ("CFC") for deemed dividends triggered when the CFC provides...more

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