U.S. Tax Review: Transition Tax, Final FTC Regs, and Priority Guidance Recommendations

In the latest installment of U.S. Tax Review, Larissa Neumann and Julia Ushakova-Stein examine the challenge to the section 965 transition tax dismissed by the Ninth Circuit; the continuing criticism from prominent stakeholders of the final foreign tax credit regulations released in January and recent responses from Treasury officials acknowledging the feedback; and the American Bar Association Section of Taxation’s recommendations for the 2022-2023 priority guidance plan, identifying high-priority focus areas.

Read the full commentary and analysis on Tax Notes.


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