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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 
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