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Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses the implications of the US Tax Court's July 13 decision in Grecian Magnesite Mining, Industrial & Shipping Co. SA v. Commissioner, where the Court rejected the IRS’s aggregate approach for taxing a foreign partner’s gain on the redemption of its US partnership interest and concluded that the foreign investor was not subject to US taxation . . .
US Treasury has identified eight tax regulations -- including the section 385 debt-equity regulations, the section 367 regulations affecting foreign goodwill and going concern value, and the section 987 foreign currency regulations -- as qualifying for revision under President Trump's executive order mandating a reduction in . . .
The OECD expects to soon release an important update to its Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, tax officials said during a June 26 webinar. Officials also discussed the OECD's coming release of a discussion draft . . .
The United States has so far put in place 11 bilateral competent authority arrangements for the automatic exchange of country-by-country reports, the OECD reported a June 22 release. The US now has . . .
Robert Stack, former deputy assistant secretary for international tax affairs at the US Treasury, has joined Deloitte, the firm announced June 20. Stack will join as a managing director of Deloitte in its . . .
Canadian and US tax officials on June 7 signed a competent authority agreement detailing the planned exchange of annual country-by-country reports on the tax affairs of multinational . . .
Eight countries are working on a new program to jointly review large multinationals' tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .
Sam Olchyk and Arthur Norman of Venable LLP, Washington. discuss a May 24 US House Ways and Means Committee hearing on tax reform where lawmakers addressed the border adjustment tax, business deductions, and passthroughs . . .