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Monthly Archives: May 2017

New Limits on Regs Trump New 385 Regs!

On November 16, 2016 we posted Treasury Issues Final & Temporary Section 385 Regs - But May Not Last Under President Trump? where we discussed that the Obama administration’s announcement of a crackdown on inversions the U.S. Treasury issued final & temporary proposed regulations that would dramatically change the taxation of corporate debt issued to related corporations…
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IRS Rescinds Termination of Foreign Certified Acceptance Agents

IRS has recently notified foreign CAAs by email that, effective Apr. 17, 2017, IRS has rescinded the termination letter that they had previously been sent.   In the email, IRS stated that if a CAA's Certified Acceptance Agent Agreement was not set to expire on Dec. 31, 2016, then no further action was required on their…
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