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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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