Author/s: North American Tax Practice Group

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In this issue:

  • Baker McKenzie Lawyers Testify at Treasury/IRS Hearing on Proposed 385 Regs
  • Brexit Update: Britain Changes Relationship Status to 'It's Complicated'
  • OECD Releases Draft Guidance on Attribution of Profits to Permanent Establishments
  • OECD Issues Discussion Draft on Profit Splits and Conforming Amendments to Transfer Pricing Guidelines
  • IRS Finalizes Regulations Allowing Outside Counsel to Conduct Summons Interviews
  • IRS Issues New Proposed Deferred Compensation Regulations, Foreshadowing Future Areas for Guidance
  • European Union Update: Disclosure of Ultimate Beneficial Owners
  • State and Local Tax Update
    • Delaware Unclaimed Property Litigation Update
    • Massachusetts Appeals Court Ignores Federal Closing Agreement in Recharacterizing Debt
    • ...And Justice for One Michigan MTC Litigant (For One Year, Maybe)...
  • Canadian Tax Update
    • Draft Legislation to Implement 2016 Canadian Federal Budget Proposals
    • Draft Legislation to Revamp the GST/HST Drop Shipment Rules
  • Final US Regulations on Country-by-Country Reporting Issued
  • IRS Releases Proposed New Q1 Agreement to Be Effective January 1, 2017
  • 2704 Proposed Regulations: Further Valuation Restrictions Imposed
  • Adjusting for the Future: New UK Transfer Pricing Rules Could Affect Finance and Royalty Structures
  • Mexican Tax Update - Reporting Obligations
  • Getting Better All the Time...US Tax Planning Capabilities Widen with New York Addition
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