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Past Their Prime: Updating the FTC Noncompulsory Rules for the Pillar 2 Era, Part 1

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Past Their Prime: Updating the FTC Noncompulsory Rules for the Pillar 2 Era, Part 1

  • By David J. Sotos, J.P. Gregorcy

David J. Sotos and J.P. Gregorcy, in the first in a two-part series, examine the history of noncompulsory payment rules under reg. section 1.901-2(e)(5) and identify areas that need clarification in light of pillar 2.

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