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Tag: 965

Dec. 31, 2018

PREVIOUSLY TAXED EARNINGS AND PROFITS (“PTEP”) UNDER THE TCJA

“Oh, how I long for the good ‘old days’ (just 2016, not far back)” Introduction For those that remember, the subpart F rules were introduced in 1962 when statutory rates were extremely high and, until December 31, 2016, we all… Read more…

Mar. 14, 2018

New Guidance on Forced / Deemed Repatriation Under IRC Section 965

By Marc Schwartz   So naïve of me. When will I learn? When Congress passed the December 2017 tax legislation, it created such complexity that my head still hurts. Focusing on the international provisions didn’t reduce the complexity. While I’ll… Read more…

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