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43 Int'l Tax J. 1 (2017)

handle is hein.journals/intaxjo43 and id is 1 raw text is: LM VOL. 43, NO. 1 JAN UARY- FEBRUARY 2017 A NOTE FROM THE EDITOR-IN-CHIEF Final Code Sec. 367(a) and (d) Regulations By Lowell D. Yoder 3 ARTICLES Code Sec. 163(j) Attributes in an M&A Deal By Stephen F Jackson and Katherine E. Loda IRS Finalizes Form 5472 Regulations for Foreign-Owned, Domestic, Disregarded Entities By Hale E. Sheppard '3 Coping with the Increasingly Stringent Global Anti-Tax Avoidance Environment: The Case of MNCs in China By Shanshan Shi Tax Treatments for Court-Free Intragroup Amalgamation in Hong Kong By Heather Lee 3 The Historical Odds of a Reversal of Altera: A 50-Year Review of Unanimous Reviewed Tax Court Opinions Reversed on Appeal ByjaredA. Hermann and Davidj. Sotos