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Treasury Department, IRS Issue Final GILTI High-Tax Exception Regulations

The final regulations addressing the GILTI high-tax exception retain the general approach of the proposed regulations with some simplifying changes. Key Points: ..Taxpayers can elect on an annual basis whether to...more

Cross-Border Financing: Taxpayer Wins on Characterization of Intercompany Debt Transaction

Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct. On August 6, 2018, the US Tax Court decided...more

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

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