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U.S. Treasury Legal History

Holland & Knight LLP

Tax Court: Conservation Easement Proceeds Regulation Is Procedurally Invalid Under APA

Holland & Knight LLP on

In holding that that Treas. Reg. § 1.170A-14(g)(6)(ii) (Proceeds Regulation) is procedurally invalid under the Administrative Procedure Act (APA), the U.S. Tax Court abandoned its precedent in Oakbrook Land Holdings, LLC v....more

Eversheds Sutherland (US) LLP

Covered Agreement - An overview

On January 13, 2017, the then-US Secretary of the Treasury and the then-US Trade Representative (USTR) notified Congress that they had negotiated a covered agreement with the European Union (EU). After a period of uncertainty...more

A&O Shearman

Regulations Proposed to Reduce Tax on Income Inclusions Under Section 956

A&O Shearman on

On October 31, 2018, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (the IRS) released proposed regulations (the Proposed Regulations) under section 956 of the Internal Revenue Code of 1986,...more

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