Donald Moorehead, partner at Squire Patton Boggs in Washington, DC, assesses the prospects for action towards US tax reform in 2015, explaining that it's no surprise many are looking back at 1986 - the last time reform was achieved - for keys to unlock the process, but significant challenges remain.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap