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New final regulations issued under Section 163(j) provide helpful clarification Larry Crouch, Kristen Garry, Todd Lowther, Michael Shulman, Austin Jones, Adam Sternberg, and other members of the Shearman & Sterling LLP Tax Department

Contributor(s): Crouch, Larry.
Material type: ArticleArticlePublisher: 2021Subject(s): SOCIEDADES EXTRANJERAS CONTROLADAS | SOCIEDADES DE INVERSION | IMPUESTOS | ESTADOS UNIDOSOnline resources: Click here to access online In: Journal of Taxation of Investments v. 38, n. 3, Spring 2021, p. 63-74Summary: This article summarizes the recent fi nal regulations issued under Section 163(j). The regulations provide rules relating to the application of Section 163(j) (enacted as part of the Tax Cuts and Jobs Act of 2017) to partnerships, controlled foreign corporations, and regulated investment companies.
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Disponible también en formato electrónico.

Resumen.

This article summarizes the recent fi nal regulations issued under Section 163(j). The regulations provide rules relating to the application of Section 163(j) (enacted as part of the Tax Cuts and Jobs Act of 2017) to partnerships, controlled foreign corporations, and regulated investment companies.

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