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Cross-Border M&A: Putting the Recently Finalized US Inversion Regulations into Context Following US Tax Reform

New regulations more notable for what they retain than what they change. Key Points: ..The US anti-inversion rules have more than a 15-year history of impacting the structure and practicality of certain cross-border...more

Withholding Guidance Issued on Sale of Interests in a Partnership with US Assets

The guidance shows Treasury Regulations will ease administrative challenges and exclude certain transfers from the new withholding regime. Key Points: ..Taxpayers can deliver IRS Form W-9 or an affidavit to establish...more

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