In this month’s installment of U.S. Tax Review, tax partners Larissa Neumann, Julia Ushakova-Stein and Mike Knobler explain the finalized IP repatriation regs, review briefs from 3M and IRS rulings regarding the section 246(b) taxable income limitation for purposes of FDII/GILTI and section 988 hedging, and describe taxpayer reactions to proposed regulations addressing disregarded payment losses and dual consolidated losses.
Read the full commentary and analysis in Tax Notes.