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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
Request for Guidance in Applying Controlled Foreign Corporation Rules following P.L. 115-97 (Repeal of Section 958(b)(4))
March 19, 2018, Covington Comment Letter to The Honorable David Kautter and The Honorable William Paul
Handling Investigations of Members of Congress and Congressional Staff
February 28, 2018, Covington Report
In the highly politicized world of investigations involving Members of Congress and congressional staff, taking the right steps in the first hours and days can mean the difference between a swift resolution and a years-long crisis.
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