19Sep
Proposed Section 382 Regulations Would Eliminate Section 338 Approach of Notice 2003-65
On September 9, 2019, the Treasury Department (“Treasury”) and the Internal Revenue Service (the IRS) issued proposed section 382 regulations (REG-125710-18) (the “Proposed Regulations”) reversing certain previously taxpayer-favorable positions...
By:
Shearman & Sterling LLP
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