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Foreign Tax Internal Revenue Service Transfer Pricing

K&L Gates LLP

The Shadow Transfer Pricing Rules: Crediting Foreign Taxes

K&L Gates LLP on

At the end of the 2013, the IRS issued, in the form of a Chief Counsel Advice [1] (CCA 201349015), its view on the applicability of transfer pricing concepts to transactions involving disregarded entities (“DEs”) in the...more

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