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We are pleased to enclose the September issue of Tax News and Developments, a publication of Baker McKenzie's North America Tax Practice Group. This month's edition features articles on the recent Treasury and IRS proposed GILTI guidance, the final regulations under section 7874, the latest IRS transactional rulings and more!

In this issue:

  • In Memoriam – David Tillinghast
  • Treasury and IRS Release Proposed GILTI Guidance
  • Treasury Finalizes Inversion Regulations
  • Making Sense of the IRS's Latest Transaction Rulings/li>
  • Another FATCA Deadline, Another Extension
  • D.C. Circuit Reverses Tax Court in Good Fortune Shipping and Applies Chevron
  • OECD Discussion Draft on Financial Transactions Under BEPS Actions 8-10
  • IRS Issues Guidance on Section 162(m) Amendments
  • Vive La (Withholding Tax) Révolution and Special Issues for US Citizens and Residents in France

 

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