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Proposed Regulation › Corporate Restructuring

Cadwalader, Wickersham & Taft LLP

Treasury Official Indicates New Taxpayer Friendly Spin-Off Regulations are Coming—But No Change in Ruling Policy in the Meantime

Cadwalader, Wickersham & Taft LLP on

At a recent conference of the American Bar Association, Treasury Associate Tax Legislative Counsel Colin Campbell Jr. stated that the recent proposed regulations governing corporate spin-off and reorganization...more

Pillsbury Winthrop Shaw Pittman LLP

Five Things You Need to Know About The “Deemed Dividend” Halloween Treat

Pillsbury Winthrop Shaw Pittman LLP on

IRS delivers a surprise in proposing new regs. New rules would generally conform the tax treatment of deemed dividends to the treatment of actual dividends for US corporations that own foreign subsidiaries, creating the...more

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