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Recent Updates
  • Commissioner Issues Temporary and Proposed Regulations on Reporting Foreign Financial Assets For Individuals and Domestic Entities.
  • Tax Notes International Highlights Year in Review for Foreign Countries: What Happened in Canada in 2011?
  • Final CFC Manufacturing Branch Regulations Released by IRS on Foreign Base Company Sales Income
  • IRS Issues Fact Sheet Providing Information on Federal Income Tax Return and Foreign Bank Filing Requirements
  • Tax Court Rules on Non-Resident, Professional Golfer's Treatment of U.S. Source Royalty and Personal Service Income in Goosen v. Commissioner, 136 T.C. No. 27 (6/9/2011).
  • Office of Chief Counsel Reports that Uncertain Tax Position Filings Were Lower Than Expected
  • Service Issues Favorable Ruling Permitting Satisfaction of the "All Events Test" for Accrual Method Taxpayer For Bonus Obligations Where Identity of Recipient and Amount of Bonus Not Yet Determined
  • Service Issues Memorandum on Application of Dual Consolidated Loss Rule Applied to a Foreign Entity that is Disregarded for U.S. Income Tax Purposes
  • Court of Federal Claims Renders Interesting Statute of Limitations Decision in Russian Recovery Fund Ltd.
  • Increased Foreign Investment In United States Requires Review of the FIRPTA Provisions
  • New Technical Interpretation Issued By Canada Revenue Agency on Stock Options Will Spark Debate
  • Tax Court Strikes Taxpayer's Expert Valuation Report as Inadmissible In Rejecting Claimed Conservation Easement Deduction in Boltar LLC et al v. Commissioner
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Federal Taxation Developments Blog
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