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Reporting Requirements Foreign Corporations Fair Market Value

Proskauer - Tax Talks

Proposed Regulations Issued on the Excise Tax on Repurchases of Corporate Stock

Proskauer - Tax Talks on

On April 9, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued two sets of proposed Treasury Regulations related to section 4501, REG-115710-22, which provides guidance on...more

McDermott Will & Emery

IRS Releases Proposed Regulations Addressing Repatriations of Intangible Property

McDermott Will & Emery on

BACKGROUND: SECTION 367(D) Section 367(d) generally addresses outbound transfers of intangible property to a foreign corporation. It treats a US transferor that transfers intangible property subject to Section 367(d) as...more

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