U.S. Tax Review: The Tax Court and Varian II: Lower-Tier Dividends Received Deductions and FTC Haircuts

In this installment of U.S. International Tax Review, tax partners Larissa Neumann and Will Skinner review the Tax Court’s Varian II considerations, the IRS’s 2025 advance pricing agreement report, and Patel and the economic substance doctrine.

Read the full commentary and analysis in Tax Notes.