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Final Regulations on Stock Owned by Domestic Partnerships under Subpart F | Freeman Law

On January 25, 2022, the Internal Revenue Services issued final regulations relating to the treatment of stock owned by domestic partnerships under certain provisions of subpart F of. ....

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Final Treasury Regulations Cushion Potential Tax Ramifications of Vanishing LIBOR | Kramer Levin Naftalis & Frankel LLP

On Jan. 4, 2022, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final regulations (the Final Regulations) offering guidance to. ....

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Is your Foreign Tax Credit really creditable? Think again: Revisiting the basics of the Foreign Tax Credit. | Freeman Law

As discussed in a previous article, the Foreign Tax Credit (FTC) is a bedrock of the U.S. tax system to reduce the impact of double taxation. In general terms, income that is derived. ....

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Treasury Finalizes Foreign Tax Credit Regulations, Including Novel Jurisdictional Nexus (Attribution) Rule - Tax

On December 28, 2021, Treasury and the IRS (collectively, Treasury) submitted another package of final foreign tax credit regulations for publication, T.D. 9959, 87 FR 276 (Final Regulations). ....

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Final IRS Regulations on Transition from LIBOR to Other Reference Rates | Dechert LLP

The U.S. Department of the Treasury and the Internal Revenue Service on December 30, 2021, issued final regulations (“Final Regulations”) allowing a tax-free treatment of “covered. ....

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