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Shareholders CFC Tax Planning

DLA Piper

What the One Big Beautiful Bill Act’s Tax Provisions Mean for Businesses Operating in Puerto Rico

DLA Piper on

President Donald Trump recently signed into law the bill commonly known as the One Big Beautiful Bill Act (OBBBA). On July 4, 2025, the OBBBA made permanent many of the provisions of the Tax Cuts and Jobs Act of 2017 (TCJA)...more

Bilzin Sumberg

Use of Estonia in U.S. International Tax Planning

Bilzin Sumberg on

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more

Bilzin Sumberg

Affirmative Use of U.S. Partnerships in Inbound Tax Planning

Bilzin Sumberg on

A “U.S. shareholder” of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of a CFC’s “subpart F” income, regardless of whether such income is distributed. In general, a CFC...more

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