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Kelley Drye & Warren LLP

Proposed Section 899 - The Retaliatory Tax Regime

Kelley Drye & Warren LLP on

The One Big Beautiful Bill Act (the ​“Bill”), which was passed by the House of Representatives on May 22, 2025, contains a provision that, if enacted in its current form, would have a dramatic impact on the U.S. tax treatment...more

Bilzin Sumberg

Cancellation of CFC Loans to US Shareholders – Should the Service Get a Second Bite at the Apple?

Bilzin Sumberg on

The Service generally has three years after a return is filed to assess any tax due for that year. There are a number of exceptions to this general rule, such as where a taxpayer files a false return or omits more than 25...more

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