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U.S. Skeptical About Permanent Safe Harbor for GLOBE Tax Framework

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Untangling Corporate AMT Regs, Loper Bright's Ongoing Effect, and Stock Buyback Regs

  • By Larissa Neumann, Julia Ushakova-Stein, and Mike Knobler

Larissa Neumann, Julia Ushakova-Stein, and Mike Knobler review the extensive proposed corporate AMT regs, explain the ongoing effect of Loper Bright, review comments on stock buyback regs, and offer updates on the Treasury Inspector General for Tax Administration’s economic substance doctrine report, taxpayers’ compliance assurance process eligibility, and IRS advice on foreign-derived intangible income and 245A dividends received deductions.

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