M&A Tax, International Tax & Tax Accounting Update 

Follow the links below to Ivins, Phillips & Barker’s M&A Tax, International Tax & Tax Accounting Update for October 2015

In This Issue:

• Recently-Issued Guidance on Outbound Transfers Reflects a Sea Change
• IRS Issues New Guidance on Tax Free Spin-offs
• D.C. District Court Allows Judicial Review of Competent Authority Discretionary Action under a Tax Treaty
• Second Circuit Denies Foreign Tax Credits on Economic Substance Grounds
• Temporary and Proposed Section 956 Regulations Address U.S. Property Held by CFCs in Transactions Involving Partnerships
• Final F Reorganization Regulations Provide Taxpayers with Additional Clarity and Flexibility
• IRS Announces Major Changes to LB&I Audit Procedures and Organizational Structure