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Business Litigation Internal Revenue Service Tax Court

McDermott Will & Emery

IRS (Belatedly) Strikes Back Against FedEx in Ongoing Foreign Tax Credit Case

McDermott Will & Emery on

FedEx Corporation, previously the victor in a closely watched dispute regarding the government’s regulatory attempt to prevent taxpayers from claiming foreign tax credits on offset earnings (131 AFTR 2d 2023-1284 (W.D. Tenn....more

Proskauer - Tax Talks

Tax Court holds that an offshore fund is engaged in a U.S. trade or business

Proskauer - Tax Talks on

On November 15, 2023, the U.S. Tax Court held in YA Global Investments v. Commissioner that a non-U.S. private equity fund (YA Global) with a U.S. asset manager that bought equity and convertible debt of U.S. portfolio...more

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