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We are pleased to enclose the May issue of Tax News and Developments, a publication of Baker McKenzie's North America Tax Practice Group. This month's edition provides updates on the "May Company" regulations, the proposed basis recovery regulations, substance over form and step transactions doctrines and more!

In this Issue

  • IRS Proposes Modifications to the "May Company" Regulations
  • IRS Withdraws the Proposed Basis Rules but Leaves the Uncertainty
  • IRS Issues Memorandum Applying Substance Over Form, Step Transaction Doctrine to Include Amounts in Taxpayer's Income Under Section 956 
  • Repeal of Section 958(b)(4) and Potential Impact on Portfolio Interest Exemption Structures
  • 2018 IRS APA Annual Report: Insufficient Resources to Accomplish its Objectives?
  • OMB Issues New Guidance to Improve Agency Compliance with the Congressional Review Act
  • California Legislature Proposes a State Gift and Estate Tax Beginning 2021
  • New QOZ Proposed Regulations Provide Much Needed Clarity to Funds and Investors
  • IRS to Obtain US Bank Information on Finnish Residents with US Bank Accounts 

The intent of this newsletter is to concentrate on current tax items that are likely to be of interest to clients and friends of our Firm.  Please feel free to pass along a copy to any of your colleagues who might also find it of interest. 


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