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Passive Foreign Investment Companies: Reinterpreting the Active Banking Exception for the Modern Banking Industry

The passive foreign investment company (“PFIC”) rules generally impose unfavorable tax treatment on certain U.S. shareholders of foreign corporations that generate excess passive income or hold excess passive assets. In...more

El Salvador Christens Bitcoin as Legal Tender

A sovereign nation’s decision to adopt Bitcoin as legal tender raises interesting questions — and legal ramifications. On June 8, 2021, El Salvador’s Legislative Assembly voted to establish Bitcoin as unrestricted legal...more

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