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Prop. Regs. Apply ‘Delta’ Approach For Dividend-Equivalent Payments To Foreign Persons

Section 871(m) was enacted in 2010 to curb the perceived abuse of foreign persons using derivatives — primarily notional principal contracts (NPCs) or swaps — to replicate the ownership of an underlying U.S. equity without...more

1/29/2014 - Dividends Foreign Nationals Income Taxes Swap Dealers Swaps Tax Evasion

Editorial: How US Cos. Can Reduce Latin American Tax Obligations

Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted through wholly-owned foreign subsidiaries. Originally Published in Law360 - October 29,...more

10/30/2013 - Corporate Taxes Foreign Subsidiaries Tax Deferral Tax Liability

Tax Planning For U.S. Companies With Latin American Operations

Pass-through structures - Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted though wholly-owned foreign subsidiaries....more

10/23/2013 - Corporate Taxes Foreign Subsidiaries Income Taxes Tax Planning

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