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Reframing the Questions Surrounding the Application of Code Sec. 245A to Controlled Foreign Corporations | Miller & Chevalier

Summary by Miller & Chevalier

Publications cridge Thu, 02/20/2025 - 09:51 Featured On Publication Name International Tax Journal Include Disclaimer Off Date 02.14.2025 Description In this article, Jeffrey Tebbs and Caroline Reaves critically analyze a controversial Advice Memorandum from the IRS Office of Associate Chief Counsel (International), which concluded that section 245A does not allow a deduction for a dividend received by a controlled foreign corporation (CFC) from…

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Miller & Chevalier

Reframing the Questions Surrounding the Application of Code Sec. 245A to Controlled Foreign Corporations | Miller & Chevalier

Publications cridge Thu, 02/20/2025 - 09:51 Featured On Publication Name International Tax Journal Include Disclaimer Off Date 02.14.2025 Description In this article, Jeffrey Tebbs and Caroline Reaves critically analyze a controversial Advice Memorandum from the IRS Office of Associate Chief Counsel (International), which concluded that section 245A does not allow a deduction for a dividend received by a controlled foreign corporation (CFC) from…

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Miller & Chevalier broke the news in 3 days ago on Thursday, February 20, 2025.

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