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Effective Dividends to Receive a 100% Deduction under New Proposed Treasury Regulations

It should come as no surprise that taxpayers seek to minimize tax liability and maximize tax benefit. One way to achieve that result is for taxpayers to ... read more >

An Inflow of Opportunity: Tax-Free Repatriation of Foreign Source Income from a Controlled Foreign Corporation

For more than fifty years, and subject to many exceptions, U.S. shareholders have been utilizing the controlled foreign corporation (“CFC”) ... read more >