Identifying obscure but potentially costly tax issues is a skill. Solving them in the context of our client’s goals is an art, and one that Paul, Weiss practices at the highest level. Working closely with the Corporate and Restructuring Departments, our tax lawyers help clients solve problems, avoid pitfalls and uncover hidden value in all types of transactions.
The New Look-Through Rule: W(h)ither Subpart F?
April 23, 2007 Full PDF
"The New Look-Through Rule: W(h)ither Subpart F?" is the topic of a Special Report, which was authored by tax partner David R. Sicular and appeared in the April 23 issue of Tax Notes. The report discusses new section 954(c)(6) from a historical, practical and policy perspective, offering suggestions for future IRS guidance and Congressional next steps.