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IRS Issues Final Regulations under Section 956, With Few Changes from Proposed Regulations

Following its issuance of proposed regulations in November of last year, the IRS today published final regulations (84 FR 23716) under Section 956 of the Internal Revenue Code. The final regulations include very few changes...more

IRS Issues Proposed Regulations under Section 956, Potentially Impacting Certain Multinational Debt Structures

The IRS recently issued proposed regulations (REG-114540-18) under Section 956 of the Internal Revenue Code limiting the effect of such section, and potentially impacting relatively standard collateral package provisions for...more

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