In their latest installment of U.S. Tax Review, co-authors James Fuller, Larissa Neuman and Julia Ushakova-Stein examine recent OECD developments, including the updated transfer pricing guidelines and the pillar 2 model rules; comments on the corporate and international tax provisions of the stalled Build Back Better Act; IRS practice units on the base erosion and anti-abuse tax and flow through foreign tax credits; and an IRS letter ruling allowing a domestic publicly traded company’s merger costs to be hedged.

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