In this installment of U.S. Tax Review, tax partners Larissa Neumann, Julia Ushakova-Stein, and Mike Knobler review the section 78 challenge in Kyocera, the Rawat and Mann cases, as well as updates on the advance pricing program, proposed section 367(d) regs, cryptocurrency developments, the Perrigo transfer pricing settlement, and new IRS practice units.
Read the full commentary and analysis on Tax Notes.