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The Superfun(d) continues! IRS issues comprehensive Superfund chemical excise tax guidance

On March 27, 2023, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued much anticipated proposed regulations, REG-105954-22 (Proposed Regulations), and additional guidance in the form of Revenue...more

Substantial Presence? PE? Treasury and the IRS prescribe treatment for tax maladies

The COVID-19 epidemic has resulted in travel restrictions around the globe, and many individuals find themselves stranded outside of the jurisdiction in which they usually work. While individuals may be able to work remotely,...more

In transition—proposed section 965 regulations incorporate and expand on prior guidance

On August 1, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations, which were published in the Federal Register on August 9, 2018 (Proposed Regulations),...more

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