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Troutman Pepper Locke

Section 899 Implications for Foreign Banks Lending to US Borrowers through US Lending Offices

Troutman Pepper Locke on

In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more

Pillsbury Winthrop Shaw Pittman LLP

Norwich v. Comm’r: Private Credit Firm Prevails in Tax Dispute to Reverse Over-Reported Income

Pillsbury Winthrop Shaw Pittman LLP on

In Norwich v. Comm’r, the taxpayer mistakenly received $7.5 million[2] as a result of various bank errors between 2007 and 2014. Not knowing that the cash was incorrectly released to it, the taxpayer reported those amounts as...more

Ballard Spahr LLP

IRS Issues Clarification Regarding Taxpayer First Act Disclosure of Information Provision

Ballard Spahr LLP on

The Taxpayer First Act adopted in the summer of 2019 includes the following provision that has an effective date of December 28, 2019...more

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