Author/s: North American Tax Practice Group 

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In this issue:

  • Proposed Regulations Under Code Section 385
  • The Facts Matter: A Setback for Guidant
  • IRS and Treasury Issue Temporary Regulations that Create More Ambiguity than Clarity on the CFTE Safe Harbor
  • As Tax Payers Increasingly Gamble and Docket in Tax Court to Get to IRS Appeals, LB&I Issues Revenue Procedure 2016-22 to Increase the House's Edge
  • Make Room for Tax Exempt and Government Entities: Rev. Proc. 2016-19 Expands the IRS's Industry Issue Resolution Program
  • 2015 IRS APA Annual Report: Increased Demand and Challenges Ahead
  • New Tax Breaks for US Taxpayers Operating and Investing in Cuba
  • New Luxembourg Tax Proposals More Careful than Bold
  • IRS LB&I Division Develops International Practice Units
  • States on the Verge of a Nexus Showdown
  • OK Computer: California Sales Tax Rules for Software Rebooted
  • Canadian Tax Update
  • Out with Audits, in with Campaigns: LB&I Reorganizes - Again
  • Final Foreign Asset Reporting Regulations for US Entities and Trusts
  • UK Changes to Royalty Taxation will Impact Multinational Groups
  • The Impact of Transfer Pricing on Compensation Deductions
  • Comment Letter Submitted to Treasury and the IRS on the FIRPTA Exemption for Qualified Foreign Pension Funds
  • Baker McKenzie Co-sponsors Global Tax Controversy and Transfer Pricing Conferences
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