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Republican Leaders Release Tax Reform Framework

The White House and Republican congressional leadership released an outline this week to guide forthcoming legislation on tax reform. This outline will serve as a useful framework in structuring what will be an active, and...more

Is a Business Tax Reform Game Plan Beginning to Take Shape?

Substantial tax reform is underway and the business community is intently awaiting details of this activity with the aim of positioning themselves to maximize opportunities and minimize any costs or risks that reform may...more

Focus on Tax Strategies & Developments - March 2015

In This Issue: - U.S. International Tax Policy: 10 Questions for 2015 - The New UK Diverted Profits Tax - France Implements Horizontal Tax Consolidation - China’s New General Anti-Avoidance Rules: An...more

3/5/2015

Courts Continue Literal Interpretation of Subpart F Rules on Income Inclusion

Consistent with prior judicial precedent, the U.S. Court of Appeals for the Fifth Circuit recently applied a literal interpretation of the Subpart F inclusion rules based on the plain meaning of Sections 951 and 956....more

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