Jonathan Zhu

Jonathan Zhu

Wilson Sonsini Goodrich & Rosati

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IRS Releases Notice Addressing the "Transition Tax" Under Section 965 of the Code

On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) released Notice 2018-26 (the Notice), which provides guidance addressing the so-called "transition tax" or "toll charge" described in...more

4/9/2018  /  Controlled Foreign Corporations , Dividends , Foreign Direct Investment , Internal Revenue Code (IRC) , IRS , Passive Foreign Investment Company , Shareholders , Tax Cuts and Jobs Act
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