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GILTI tax Foreign Investment Controlled Foreign Corporations

Venable LLP

International Tax Reform Under the "One Big Beautiful Bill": What Global Businesses Need to Know

Venable LLP on

As the U.S. Senate is set to consider President Trump's domestic policy bill, non-U.S.-based multinational businesses and non-U.S. investors are preparing for wholesale changes to the U.S. international tax landscape,...more

Proskauer - Tax Talks

New Repatriation Tax Relief for RICs and Foreign Income Guidance for REITs

Proskauer - Tax Talks on

On September 6, the Internal Revenue Service (“IRS”) released Revenue Procedure 2018-47 (the “RIC Rev Proc”) which provides that, a repatriation deemed to have been received by a registered investment company (a “RIC”) under...more

Orrick, Herrington & Sutcliffe LLP

U.S. Tax Reform Has A Profound Impact On Inbound Investment

The current focus of the international tax community is on the United States, and for good reason. In the midst of a contentious political landscape, months of anticipation, and a decidedly clandestine drafting process, U.S....more

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