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Business Profits Internal Revenue Code (IRC)

Eversheds Sutherland (US) LLP

Treasury and the IRS address classification and ordering rules for previously taxed earnings and profits of foreign corporations

On December 14, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued guidance (Notice 2019-01 or the Notice) describing proposed regulations that they intend to issue addressing...more

Pierce Atwood LLP

New Hampshire Enacts Business-Friendly Tax Changes

Pierce Atwood LLP on

Three business-friendly tax bills have become law in New Hampshire. Each bill will result in tax reductions for those able to take advantage of them. The New Hampshire Business Profits Tax generally “piggybacks” on the...more

Patterson Belknap Webb & Tyler LLP

Entering the U.S. Without Entering Its Tax System: Holding Company Structures for U.S. Operations

Foreign companies entering the U.S. market for the first time will want to consider how their operations can be structured to minimize U.S. taxes. Although sales into the U.S. can be arranged in some cases to keep profits...more

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