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International Tax Issues New York City 2020
Michael A. DiFronzo
International Law, Tax
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Table of Contents
Table of Contents
Chapter 1. U.S. Issues Taxpayer-Favourable Regulations under GILTI and Subpart F Regimes
Chapter 2. U.S. Proposed Regulations Target Hybrid Structures and Instruments Retroactively
Chapter 3. IRS Proposes Regulations That Would Liberally Apply Exemption from FIRPTA to Qualified Foreign Pension Funds
Chapter 4. IRS Proposes New Rules for Withholding on Interest Transfers in Certain Partnerships
Chapter 5. KPMG Comment—Comments on Discussion Draft: Revised Guidance on Profit Splits (September 15, 2017)
Chapter 6. KPMG Comment—Comments on Discussion Draft: Additional Guidance on Attribution of Profits to Permanent Establishments (September 2017)
Chapter 7. EY Alert, Final and Proposed Regulations Provide Additional Guidance for Determining Allowable Foreign Tax Credits, No. 2019-2155 (December 8, 2019)
Chapter 8. Latham & Watkins, Client Alert Commentary, Final Section 956 Regulations Open the Door to Foreign Credit Support for US Corporate Borrowers, No. 2509 (June 3, 2019)
Chapter 9. Latham & Watkins, Client Alert Commentary, IRS Issues Guidance on Transfers by Non-US Partners of Interests in Partnerships with US Assets, No. 2431 (January 10, 2019)
Chapter 10. Latham & Watkins, Client Alert Commentary, IRS Issues Proposed Regulations on Business Interest Deduction Limitations, No. 2423 (December 19, 2018)
Chapter 11. In Search of a Normative Theory of Partnership Taxation for International Tax (or How We Learned to Stop Worrying and Love Subchapter K) (January 2015)
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