The North America Tax Practice group provides updates on the final and proposed GILTI regulations, developments under the Taxpayer First Act, a discussion on the Grecian Magnesite Mining v. Commissioner case and more in their July issue of Tax News and Developments.
In this issue:
- The Aggregate Approach to Partnerships -- (Almost) Always the Right Result?
- Key Developments Under the Taxpayer First Act
- D.C. Circuit Court of Appeals Pins IRS in Grecian Magnesite Mining case, but a Hollow Victory for Taxpayers Prospectively
- Ninth Circuit Upholds Validity of Cost-Sharing Regulations in Altera
- Section 956 Final Regulations Provide Two Modifications from Proposed Regulations
- Grasping for Simplicity, Beyond Arm's Length: OECD Releases its "BEPS 2.0" Work Program
- IRS Issues Proposed Regulations on Section 3405 Withholding
- Clarification Only: IRS Finalizes Regulations Regarding Properties Transferred to REITs Following a Section 355 Distribution with Minimal Change
- Canada Revenue Agency Releases a Notice to Tax Professionals on Hybrid Financing into Canada
- IRS Concedes Position on Creditability of French Social Charges
- Treasury and IRS Release Temporary Regulations Under Sections 245A and 954(c)(6)
- Treasury and IRS Release Final and Proposed Regulations on GILTI