US: Foreign-controlled CFCs - assessing the regulations for dealing with downward attri... William Skinner and Mike Knobler of Fenwick & West evaluate the final regulations, which had sought to address unintended consequences caused by the earlier repeal of Section 958(b)(4)’s limitation on... By William Skinner & Mike Knobler October 28 2020
Section 163(j): A closer look at inbound financing developments in the US William Skinner and Mike Knobler of Fenwick & West discuss the practical implications for foreign-parented groups from the final §163(j) regulations. By William Skinner & Mike Knobler September 30 2020