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SPAC merger said to satisfy COBE requirement by Robert Willens

By: Willens, Robert.
Material type: ArticleArticleSubject(s): CONCENTRACION | SOCIEDADES DE ADQUISICIÓN CON FINES ESPECIALES | NEGOCIOS MERCANTILES | ESTADOS UNIDOS In: Tax Notes International v. 107, n. 3, July 18, 2022, p. 323-326Summary: In this article, the author sets out a pillar 1 design proposal that leverages pillar 2 to reallocate taxing rights to market jurisdictions and avoid double taxation without requiring amendments to U.S. tax treaties.
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Resumen.

In this article, the author sets out a pillar 1 design proposal that leverages pillar 2 to reallocate taxing rights to market jurisdictions and avoid double taxation without requiring amendments to U.S. tax treaties.

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