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IRS Issues Proposed Regulations On Section 951(a)(2)(B) Planning - Tax Authorities

Published: January 4, 2023

On December 9, 2022, Treasury and the IRS released proposed regulations that are intended to stop certain U.S. shareholder tax planning under section 951(a)(2)(B).

Source: mondaq.com

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Group Rules ApplicableProposed RegulationsCurb SectionConsolidated GroupsProposed RegulationTested IncomePreviously Taxed EarningsTax CutsJobs ActFederal RegisterTreasury DecisionConsiderations RaisedIrs Issues Proposed Regulations On Section 951a 2b PlanningCorporate Commercial LawCorporate And Company LawTax AuthoritiesTransfer Pricing

IRS Issues Proposed Regulations on Section 951(a)(2)(B) Planning | Freeman Law

Published: December 19, 2022

Introduction: Consolidated Groups and Section 951(a)(2)(B) Tax Planning - On December 9, 2022, Treasury and the IRS released proposed regulations that are intended to...

Source: jdsupra.com

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Group Rules ApplicableConsolidated GroupsProposed RegulationTested IncomePreviously Taxed EarningsTax CutsJobs ActFederal RegisterTreasury DecisionConsiderations Raised