The IRS recently issued a Chief Counsel Advice Memorandum (AM 2025-002) (the CCA) that provides helpful guidance regarding the application of the branch profits tax (BPT) in connection with reverse ...
In a general legal advice memorandum dated September 8, 2025, with a release date of September 19 (the “GLAM”),1 the Chief Counsel’s office of the Internal Revenue Service (“IRS”) addressed the ...
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