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Tax Court Overturns IRS Cost-Sharing Regulation
Joseph A. Goldman,Karl L. Kellar,Edward T. Kennedy,Jerry N. Smith,Raymond J. Wiacek, August 6, 2015
On July 27, 2015, in Altera Corporation v. Commissioner, 145 T.C. No. 3 (2015), the Tax Court held Treasury regulation section 1.482-7(d)(2) (the "Regulation") invalid. This decision is significant to taxpayers who are parties to cost-sharing arrangements with foreign affiliates but, if...
U.S. Treasury Department Releases Proposed Model Treaty Provisions
Lodewijk P.W. Berger,Patrick J. Browne,Joseph A. Goldman,Karl L. Kellar,Raymond J. Wiacek, June 8, 2015
On May 20, 2015, the U.S. Treasury Department released for public comment draft updates to the U.S. model income tax convention and its accompanying Technical Explanation (collectively, the "Model Treaty"), which was last updated in 2006. The Model Treaty is the template that Treasury...