Washington Dispatch - June 2006

IRS Issues Proposed Regs Under Sections 367, 1248 -- IRS Temp and Prop Regs Target Cross-Border Inversion Transactions -- IRS Notice 2006-46 Announces Coming Final Regs on Transfer of US Real Property Interests -- PLR 200620017: Finco May Satisfy Active Trade or Business Test Via Activities of Connected Persons -- Coming IRS Rev Proc Will Allow Taxpayers to Change Methods of Interest, R&E Apportionment Without Prior Consent -- US Signs Tax Protocols with Finland, Germany


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