By Bill Pauls and Michael Miles, Sutherland
Asbill & Brennan LLP
On July 30,
2012, the IRS Large Business & International (LB&I) Division issued
guidelines intended to reduce the controversy associated with partial
By Robb Chase, Reggie Clark, Jeff Mace, Michael Miles, Carol Tello, Karl Zeswitz, Saren Goldner, and Bill Pauls, Sutherland Asbill & Brennan LLP
On June 7, 2012, Treasury and the Internal Revenue Service (the IRS) issued much-anticipated final...