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The North America Tax Practice group provides updates on the Altera opinion, Treasury’s proposed regulations implementing the TCJA, the 2016 debt-financed temporary regulations and more in their August issue of Tax News and Developments.

In this Issue:

  • Here Today, Gone Tomorrow: Ninth Circuit Issues, then Withdraws, Opinion in Altera
  • How I Spent My Summer Vacation—Reading Proposed Regulations
  • Proposed Regulations Under Section 965
  • IRS Withdraws 2016 Temporary Regulations Affecting Debt-Financed Distribution Exception to Disguised Sale Treatment
  • Section 987 Regulations are Further Delayed and Onerous Section 385 Documentation Rules to be Withdrawn
  • IRS Issues Final Regulations on Inversions
  • OECD Releases Final Guidance on Key Topics of BEPS Actions 8 to 10
  • Beware of New EU Reporting Obligations Ahead: EU Adopts Directive on Mandatory Disclosure of Cross-Border Tax Arrangements (Covering Arrangements as of June 25, 2018)
  • Taxpayer's Deduction of Payment to Russian Subsidiary Denied as Bad Debt and Business Expense
  • Clear Intent Still Won't Dictate Deductibility for Settlement Agreement Amounts
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