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03.12.2025

Firm Publication

Proposed Section 355 Regulations Address Delayed Distributions and Add Reporting Requirements

Tax Alert

06.03.2024

Firm Publication

Monthly Tax Roundup (Volume 3, Issue 6)

Tax Alert

02.01.2024

Firm Publication

Monthly Tax Roundup (Volume 3, Issue 2)

Tax Alert

09.05.2023

Firm Publication

Monthly Tax Roundup (Volume 2, Issue 8)

Tax Alert

03.01.2022

Firm Publication

Monthly Tax Roundup (Volume 1, Issue 1)

Tax Alert

06.24.2019

Firm Publication

Treasury Releases New Regulations Providing Guidance Under GILTI and Participation Exemption

Tax Alert

12.20.2018

Firm Publication

BEAT Proposed Regulations Provide Important Guidance

Tax Alert

11.29.2018

Firm Publication

Proposed Regulations Extend Section 163(j) to CFCs

Tax Alert

02.21.2018

External Publication

IRS Expands Scope of Private Letter Ruling Program for Spin-offs

10.02.2017

Firm Publication

IRS Expands Scope of Private Letter Ruling Program for Spin-offs

Tax Alert

08.03.2017

External Publication

IRS Comments on North/South Ruling and Current Ruling Posture for Section 355 Transactions

05.22.2017

Firm Publication

IRS Comments on North/South Ruling and Current Ruling Posture for Section 355 Transactions

Tax Alert

07.22.2016

Firm Publication

Section 355 Guidance Imposes New Minimum Thresholds for Business Assets and Provides Safe Harbors for Control/Unwind Transactions

Tax Alert

09.29.2015

Firm Publication

Treasury Issues Final Regulations on F Reorganizations; Overlap Issues Clarified

Tax Alert

07.19.2011

Firm Publication

IRS Issues Internal Guidance on Codified Economic Substance Doctrine

Tax Controversy Alert

11.15.2010

Firm Publication

"Top 10" Year-End Tax Planning Strategies in Light of 2010 Tax Legislation

Tax Alert

04.05.2010

Firm Publication

Practical Implications of the Codification of the Economic Substance Doctrine

Tax Alert

02.08.2006

Firm Publication

Amtrak Prevails in Refund Suit Involving the Federal Communications Excise Tax

Tax Controversy Alert

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publications

Proposed Section 355 Regulations Address Delayed Distributions and Add Reporting Requirements

Monthly Tax Roundup (Volume 3, Issue 6)

Monthly Tax Roundup (Volume 3, Issue 2)

Monthly Tax Roundup (Volume 2, Issue 8)

Monthly Tax Roundup (Volume 1, Issue 1)

Treasury Releases New Regulations Providing Guidance Under GILTI and Participation Exemption

BEAT Proposed Regulations Provide Important Guidance

Proposed Regulations Extend Section 163(j) to CFCs

IRS Expands Scope of Private Letter Ruling Program for Spin-offs

IRS Expands Scope of Private Letter Ruling Program for Spin-offs

IRS Comments on North/South Ruling and Current Ruling Posture for Section 355 Transactions

IRS Comments on North/South Ruling and Current Ruling Posture for Section 355 Transactions

Section 355 Guidance Imposes New Minimum Thresholds for Business Assets and Provides Safe Harbors for Control/Unwind Transactions

Treasury Issues Final Regulations on F Reorganizations; Overlap Issues Clarified

IRS Issues Internal Guidance on Codified Economic Substance Doctrine

"Top 10" Year-End Tax Planning Strategies in Light of 2010 Tax Legislation

Practical Implications of the Codification of the Economic Substance Doctrine

Amtrak Prevails in Refund Suit Involving the Federal Communications Excise Tax

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