Works matching DE "TAXATION of controlled foreign corporations"
Results: 36
Part V: Section 965 Transition Tax: Yes, some issues are likely to persist for years after you've paid the tax.
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- Tax Executive, 2019, v. 71, n. 2, p. 47
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- Article
RESTRAINING HARMFUL TAX COMPETITION: AN ANALYSIS OF AMERICAN CFC LEGISLATION.
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- Economics & Law / Ekonomia i Prawo, 2014, v. 13, n. 3, p. 377, doi. 10.12775/EiP.2014.027
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- Article
First Look at the Tax Cuts and Jobs Act: Impact of 'GILTI' on International Taxpayers.
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- CPA Journal, 2018, v. 88, n. 4, p. 22
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- Article
Is Code Sec. 1291(f) Self-Executing?
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- International Tax Journal, 2021, v. 47, n. 1, p. 5
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- Article
The GILTI and Subpart F Income High-Tax Exception(s).
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- International Tax Journal, 2020, v. 46, n. 6, p. 3
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- Article
Will the Overlap Rule of Code Sec. 1297(d) Still Protect "Small" Partners of Domestic Partnerships?
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- International Tax Journal, 2020, v. 46, n. 3, p. 15
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- Article
Subpart F Sales Income.
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- International Tax Journal, 2020, v. 46, n. 3, p. 3
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- Article
Direct, Indirect, or Barely Connected: Rev. Proc. 2019-40 Provides Limited Relief to U.S. Persons Surprised by CFC Ownership.
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- International Tax Journal, 2020, v. 46, n. 1, p. 37
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- Article
Foreign Investment in Qualified Opportunity Zones by Foreign Taxpayers and CFCs.
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- International Tax Journal, 2020, v. 46, n. 1, p. 17
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- Article
The Proposed GILTI High-Tax Exception.
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- International Tax Journal, 2019, v. 45, n. 4, p. 3
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- Article
Taxation of CfC Income: The Paradigm.
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- International Tax Journal, 2019, v. 45, n. 3, p. 3
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- Article
Checking-and-Selling a Lower-Tier CFC.
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- International Tax Journal, 2019, v. 45, n. 2, p. 3
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- Article
International Corporate Tax Reform and Partnership Taxation: Fitting a Triangular Peg into a Rectangular Hole.
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- International Tax Journal, 2018, v. 44, n. 4, p. 6
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- Article
GILTI, FDII, and the Future of International IP Planning.
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- International Tax Journal, 2018, v. 44, n. 3, p. 31
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- Article
Deduction for FDII.
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- International Tax Journal, 2018, v. 44, n. 2, p. 3
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- Article
International Tax Reform: Planning Signposts for U.S. Multinationals.
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- International Tax Journal, 2018, v. 44, n. 1, p. 3
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- Article
Fixing the Code Sec. 956 Formed or Funded Rule.
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- International Tax Journal, 2017, v. 43, n. 2, p. 33
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- Article
The Latest Killer B Notice.
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- International Tax Journal, 2017, v. 43, n. 2, p. 17
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- Article
Section 956 in the Partnership World: An Aggregate Tour de Force with Some Bumps in the Road.
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- International Tax Journal, 2017, v. 43, n. 2, p. 5
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- Article
Applying the Subpart F Services Rules to Regarded Entity Structures.
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- International Tax Journal, 2015, v. 41, n. 6, p. 3
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- Article
Foreign Tax Credits.
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- International Tax Journal, 2015, v. 41, n. 3, p. 5
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- Article
Obama Administration Proposes a 19-Percent Minimum Tax on Foreign Earnings.
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- International Tax Journal, 2015, v. 41, n. 3, p. 3
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- Article
IRS Expands the Application of the Code Sec. 956 Anti-Conduit Rule.
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- International Tax Journal, 2015, v. 41, n. 2, p. 3
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- Article
Notice 2014-52: IRS Attempts to Shut the Door on Inversions.
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- International Tax Journal, 2014, v. 40, n. 6, p. 27
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- Article
Extending the 2009 Code Sec. 367 GRA Triggering Event Exceptions to Accommodate a Foreign-to- Foreign Code Sec. 304 Transaction.
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- International Tax Journal, 2014, v. 40, n. 3, p. 9
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- Article
A Note From the Editor-in-Chief.
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- 2014
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- Publication type:
- Editorial
Brazilian CFC Rules and Indirect Controlled Foreign Companies: Recent Case Laws and Consequences of Supreme Court Precedent.
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- International Tax Journal, 2013, v. 39, n. 3, p. 23
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- Article
A Note From the Editor-in-Chief.
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- International Tax Journal, 2011, v. 37, n. 2, p. 3
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- Article
International Tax Controversies.
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- International Tax Journal, 2009, v. 35, n. 4, p. 5
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- Article
International Tax Issues.
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- International Tax Journal, 2009, v. 35, n. 3, p. 13
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- Article
Financing International Operations.
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- International Tax Journal, 2008, v. 34, n. 3, p. 13
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- Article
UPDATE ON US CORPORATE IN VERSIONS.
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- Canadian Tax Journal / Revue Fiscale Canadienne, 2014, v. 62, n. 4, p. 1203
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- Article
A New Tax Regime for CFCs: Who Is GILTI?
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- Journal of Taxation & Regulation of Financial Institutions, 2018, v. 31, n. 3, p. 17
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- Article
Tax Avoidance through Controlled Foreign Companies under European Union Law with Specific Reference to Poland.
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- Accounting, Economics & Law, 2017, v. 7, n. 1, p. 69, doi. 10.1515/ael-2015-0018
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- Article
Choice Of Entity Corner: S Corporations and the New International Tax Provisions of the TCJA.
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- Journal of Passthrough Entities, 2018, v. 21, n. 5, p. 7
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- Article
International Tax Issues Corner.
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- Journal of Passthrough Entities, 2016, v. 19, n. 2, p. 15
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- Article