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Final Section 162(f) Regulations Liberalize Opportunities to Deduct Disgorgement and Other Payments Made in Government...

On January 12, 2021, the Internal Revenue Service (IRS) and the Treasury Department released final regulations governing the deductibility of certain fines, penalties and other amounts paid to, or at the direction of, a...more

USTR Launches Section 301 Probe of France's Digital Services Tax

The Office of the U.S. Trade Representative (“USTR”) announced on July 10 the initiation of an investigation under Section 301 of the Trade Act of 1974 into France’s digital services tax (“DST”). The French Senate...more

Tax Act: Significant International Provisions

Prior to the Tax Act, the principal method for avoiding the double taxation of overseas corporate earnings—once by the local country and a second time by the United States as the multinational's home country—was the foreign...more

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