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- Treatment of Section 78 Gross Up Amounts Relating to Section 960 b Foreign Income Taxes
Treatment of Section 78 Gross-Up Amounts Relating to Section 960(b) Foreign Income Taxes
July 22, 2018, Covington White Paper
Comments on Section 59A Proposed Regulations (Internal Revenue Service REG–104259–18) – Applicability of BEAT to Global Services Provided by U.S. Equipment Manufacturers
February 19, 2019, Covington Comment Letter
Comments on Section 59A Proposed Regulations (Internal Revenue Service REG–104259–18) – Treatment of a Loss Recognized upon the Transfer of Property
February 19, 2019, Covington Comment Letter
BEAT Implementation Proposals Related to Global Services Operations
July 18, 2018, Covington White Paper