On December 28, 2018, the Office of the United States Trade Representative (USTR) published a list of 31 products that were granted a one-year exclusion from the tariffs imposed on Chinese goods pu
In this article, James Tillen and Ann Sultan analyze 2018 enforcement trends to make th
On December 13, 2018, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 59A, the base erosion and anti-ab
On November 20, 2018, the Internal Revenue Service's (IRS) Criminal Investigation Division (CI) issued a memorandum (the Updated Practice) providing significant guidance on voluntary disclosures (b
On November 26, 2018, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 163(j).1 The 2017 Tax
In this article, Layla Asali, Andrew Howlett, Katherine Zhang,* and David Zimmerman discuss Revenue Procedure 2017-52, which describes the Internal Revenue Service's (IRS's) pilot program that expa
On September 21, 2017, the Internal Revenue Service (IRS) introduced a pilot program that expands the scope of letter rulings available for distributions intended to qualify as tax-free spin-offs u
In this article, David Zimmerman, Layla Asali, A
On April 4, 2016, proposed regulations ("Proposed Regulations") under Internal Revenue Code section 3851 were issued that generally recharacterize related party debt as equity in whole o
On Thursday, November 19, 2015, the U.S.
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