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- Comments on Section 965 Proposed Regulations Internal Revenue Service REG 104226 18 Downward Attribution Under Section 318 in Examples 1and 2 of Proposed Treasury Regulation Section i 965 i g
Comments on Section 965 Proposed Regulations (Internal Revenue Service REG-104226-18) - Downward Attribution Under Section 318 in Examples 1 & 2 of Proposed Treasury Regulation Section 1.965-1(g)
September 24, 2018, Covington Comment Letter
March 26, 2020, Covington Alert
Late last night, the Senate passed (96-0) the Coronavirus Aid, Relief, and Economic Security ("CARES") Act that was introduced by several Senate Republicans last Thursday. This follows a number of days of whirlwind negotiations, beginning with the Senate where, on Sunday night, a procedural vote failed to garner the 60 votes necessary to move the legislation ...
Clarifications On Tax Reform Will Come, Officials Say
January 25, 2018, Law360
Michael Caballero spoke at a tax conference in Washington and is quoted in a Law360 article regarding the recently enacted U.S. tax legislation. According to Caballero, the tax law’s creation of reasonably low-tax foreign income that’s now returned means that “we’ve got partially exempt and partially taxed income that we now have to take and push through the ...
November 13, 2017, Tax Analysts
Michael Caballero is quoted in a Tax Analysts article regarding how the tax reform bill further complicates the foreign tax credit (FTC). The current FTC rules are "insanely complex," says Caballero. "The one thing that's not in this bill, at least on the international side, is an ounce of simplification."