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US Senate Finance Committee Makes Changes to Proposed Section 899

The US Senate Finance Committee has released a substitute (the “Senate version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently under consideration by Congress. An earlier...more

Capital Markets Tax Quarterly - January 2020

On December 16, 2019, the IRS released Notice 2020-2 (the “Notice”), which further extends the phase-in of regulations under Section 871(m) of the Code3 (the “Regulations”)4 and related provisions. Section 871(m) and its...more

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