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MEDIA CONTACT

Julie Merkin
Director of Marketing

jmerkin@milchev.com

202.661.5413

publications

Displaying 179 results
Firm Publication

Treasury and IRS Issue Proposed Regulations on OBBBA Pro Rata Share Rules

Tax Alert
Firm Publication

Anti-abuse Rule Results in Denial of Qualified Dividend Treatment and Associated Foreign Tax Credits

Tax Alert
Firm Publication

Proposed Regulations Would Allow Election Out of Section 987 Compliance for CFCs

Tax Alert
External Publication

PTEP and Partnerships: A Study

Firm Publication

Treasury Provides Transition Relief in New Proposed Regulations Under Section 892

Tax Alert
Firm Publication

TAX TAKE: No Summer Vacation (Yet) From Multilateral Tax Initiatives

Tax Alert
Firm Publication

Tax Court Resolves Collateral Issues in Favor of IRS in Varian

Tax Alert
Firm Publication

United States and Croatia Sign Protocol Updating Pending 2022 Income Tax Treaty

Tax Alert
Firm Publication

Latest Interim Guidance on CAMT Includes Relief for Domestic R&E Expenditures, Repairs, and Intangibles

Tax Alert
Firm Publication

Notice 2026-15 Provides Guidance on Evaluating Material Assistance for Section 45Y, 45X, and 48E Tax Credit Purposes

Tax Alert
Firm Publication

Treasury Finalizes and Proposes Regulations Under Section 892 Exemption for Foreign Sovereigns

Tax Alert
Firm Publication

IRS Clarifies Sourcing Rules for Borrow Fees in Securities Lending Transactions

Tax Alert
Firm Publication

Treasury and IRS Provide Initial Guidance on OBBBA International Tax Provisions

Tax Alert
Firm Publication

TAX TAKE: U.S. Tax Legislation May Ride on International Tax Discussions

Tax Alert
Firm Publication

District Court Strictly Applies Repeal of Subpart F Downward Attribution Rules in Altria

Tax Alert
Firm Publication

IRS Announces Changes to CAMT Proposed Regulations

Tax Alert
Firm Publication

IRS Releases Informal Guidance on Application of Treaties to Branch Profits Tax of Reverse Hybrids

Tax Alert
Firm Publication

Perrigo Opinion Upholds Economic Substance of Intercompany Assignment of Contract Rights

Tax Alert
Firm Publication

Treasury and IRS Announce Rules Facilitating Inbound F Reorganizations Involving U.S. Real Property Interests and Permitting Share Transfers in Multi-Step F Reorganizations

Tax Alert
Firm Publication

Sixth Circuit Upholds IRS Summons Seeking Foreign Employee Records in Eaton

Tax Alert

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