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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...
Treasury Department and IRS Issue Long-Awaited Inversion Guidance
Lester W. Droller,Andrew M. Eisenberg,Andrew M. Levine,Robert A. Profusek,Raymond J. Wiacek, September 25, 2014
On September 22, 2014, the U.S. Treasury Department and the IRS issued long-awaited inversion guidance in the form of Notice 2014-52. The Notice sets forth rules that are generally effective for acquisitions completed on or after September 22, 2014, and will be included in regulations that will be...