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IRS Releases Additional Tax Guidance on the Transition from Interbank Offered Rates

On October 12, 2020, the Internal Revenue Service issued Revenue Procedure 2020-44 (the Revenue Procedure) providing additional guidance related to the transition from an interbank offered rate (IBOR) to another replacement...more

Guidance on CFC ‘Downward Attribution Rules’ Provides Limited Relief to US Taxpayers

On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more

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