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Proposed U.S. regs narrow GILTI exposure on Canadian CFC operations by Nathan Boidman

By: Boidman, Nathan.
Contributor(s): Tang, Reynah.
Material type: ArticleArticlePublisher: 2019Subject(s): SOCIEDADES EXTRANJERAS CONTROLADAS | ACCIONISTAS | IMPUESTOS | ESTADOS UNIDOS | CANADA In: Tax Notes International v. 94, n. 10, June 3, 2019, p. 995-997Summary: The Tax Cuts and Jobs Act adopted the idea that U.S. shareholders should be immediately taxed on some portions of hte purely active business profits of controlled foreign corporations. In this article, the author examines how that rule, as modified by recently proposed regulations, would affect Canadian CFCs.
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OP 138-Bis/2019/94/10-4 (Browse shelf) Available OP 138-Bis/2019/94/10-4

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Resumen.

The Tax Cuts and Jobs Act adopted the idea that U.S. shareholders should be immediately taxed on some portions of hte purely active business profits of controlled foreign corporations. In this article, the author examines how that rule, as modified by recently proposed regulations, would affect Canadian CFCs.

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