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Comments on Section 59A Proposed Regulations (Internal Revenue Service REG–104259–18) – Proposals Regarding TLAC Securities, Securities Lending Transactions, and Internal Dealings
February 19, 2019, Covington Comment Letter
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
Comments on Section 965 Proposed Regulations (Internal Revenue Service REG-104226-18) - Downward Attribution Under Section 318 in Examples 1 & 2 of Proposed Treasury Regulation Section i.965-i(g)
September 24, 2018, Covington Comment Letter
Treatment of Section 78 Gross-Up Amounts Relating to Section 960(b) Foreign Income Taxes
July 22, 2018, Covington White Paper
BEAT Implementation Proposals Related to Global Services Operations
July 18, 2018, Covington White Paper
Proposed Guidance Regarding the Treatment of Income from Banking Under Section 199A
June 7, 2018, Covington Comment Letter to The Honorable David J. Kautter and The Honorable William M. Paul
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