North America Tax News and Developments – December 2016
Author/s: North America Tax Practice
We are pleased to enclose the December issue of Tax News and Developments, a publication of Baker McKenzie's North American Tax Practice Group. The December edition features articles on tax reform and the recent election results, the Tax Court's ruling in Analog Devices, as well as recent developments in Canadian and state and local tax. A complete list of articles is available below.
In this Issue
- Understanding the 2016 Election Results and their Impact on Tax Reform
- PLR 201643008: IRS Applies Expansion Doctrine When Corporation Proposes to Spin-Off Subsidiary that Holds Recently-Acquired Partnership Interest
- Analog Devices Reverses BMC Software on Section 965 Dividend Received Deduction
- US Treasury Announces Final CFC/Partnership Regulations, Which are a lot like the Temporary Regulations
- IRS Reconsiders the Treatment of M&A Termination Fees
- Even if the Proposed 2704 Regulations Don’t Get Trumped, it May Not be as Bad as we Thought
- State and Local Tax Update
- South Carolina Department of Revenue Appeals Rent-A-Center Decision
- Mississippi Supreme Court Finds Differing Treatment of Dividends Unconstitutional
- Canadian Tax Update
- Canada Revenue Agency Insights into LLPs, LLLPs, and BEPS Action Item 13
- Baker McKenzie Tax Teams with Tax Executives Institute in Toronto for our 39th Annual North America Tax Conference-- and You're Invited!