IRS/Treasury guidance plan will likely affect all companies with global structures

November 2012


Companies with cross-border business activities will likely be affected by the international tax regulatory projects included in the IRS/Treasury’s’ 2012-2013 Priority Guidance Plan. The annual business plan announces the regulatory projects that the Administration hopes to complete during the plan year, which runs from July to June. Projects of particular interest include those finalizing the currency exchange regulations under section 987; rules implementing the 2010 legislation limiting foreign tax credit treatment related to section 956 loans and certain cross-border asset acquisitions; and the foreign tax credit regulations addressing foreign tax redeterminations.

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Doug McHoney
Co-leader, US Integrated Global Structuring team
Tel: +1 (312) 298 2527

Calum Dewar
Co-leader, US Integrated Global Structuring team
Tel: +1 (646) 471 5254

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