As the US economy continues to sputter, it is perhaps not surprising that Congress and the administration have looked to change the country’s international tax rules to increase revenue. David Forst and Adam Halpern, partners at Fenwick & West, explain some of these changes, including legislative developments and new case law that will have implications for multinational corporations.
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
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