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International Tax Issues New York City 2019
Michael A. DiFronzo
International Law, Tax
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Table of Contents
Table of Contents
Chapter 1. The Impact of U.S. Tax Reform on Canada-U.S. M&A (November 6, 2018)
Chapter 2. KPMG Comment—Comments on Discussion Draft: Revised Guidance on Profit Splits (September 15, 2017)
Chapter 3. KPMG Comment—Comments on Discussion Draft: Additional Guidance on Attribution of Profits to Permanent Establishments (September 2017)
Chapter 4. Latham & Watkins Client Alert Commentary: New Proposed Treasury Regulations May Eliminate Adverse Tax Consequences on Use of Foreign Credit Support for US Corporate Borrowings, No. 2405 (November 5, 2018)
Chapter 5. Latham & Watkins Client Alert Commentary: Cross-Border M&A: Putting the Recently Finalized US Inversion Regulations into Context Following US Tax Reform, No. 2355 (July 26, 2018)
Chapter 6. Latham & Watkins Client Alert Commentary: Withholding Guidance Issued on Sale of Interests in a Partnership with US Assets, No. 2298 (April 5, 2018)
Chapter 7. Latham & Watkins White Paper, US Tax Reform: Key Business Impacts, Illustrated with Charts and Transactional Diagrams, No. 2266 (January 10, 2018)
Chapter 8. PwC Knowledge & Insight: IRS Issues Proposed Rules on ‘GILTI’ under Section 951A (September 28, 2018)
Chapter 9. PwC Knowledge & Insight: Treasury Issues Proposed Rules Related to Foreign Tax Credits (December 14, 2018)
Chapter 10. PwC Knowledge & Insight: Proposed Regulations Would Reduce Section 956 Amounts for Domestic Corporations (November 2, 2018)
Chapter 11. PwC Knowledge & Insight: Treasury Releases Notice 2019-01—Previously Taxed Earnings and Profits Accounts (December 14, 2018)
Chapter 12. PwC Knowledge & Insight: Preliminary Highlights of the Proposed BEAT Regulations (December 14, 2018)
Chapter 13. New York State Bar Association, Tax Section, Report No. 1394 on the GILTI Provisions of the Code (May 4, 2018)
Chapter 14. Congressional Research Service, Issues in International Corporate Taxation: The 2017 Revision (P.L. 115-97) (May 1, 2018)
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