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Biden's tax strategy is quiet on whether the section 962 election's 80% limitation on foreign tax obligations will...

Companies must potentially account for situations in which a circulation is made by a first-tier CFC which holds lower-tier CFCs, is...

e., indirectly very own much less than 10% rate of interest in a collaboration CFC), but...

Such funds structured as corporates for United States tax category functions, must be thought about non-US situs assets...