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Substantiating an FDII Deduction: Certain Deal-Related Considerations Raised by New Regulations

One of the cornerstones of the current U.S. international tax system, as revised under the 2017 tax law commonly known as the Tax Cuts and Jobs Act, is the deduction provided to U.S. corporate taxpayers under section 250(b)...more

Payroll Tax Deferral: Uncertainties Remain One Week Prior to Start of Applicable Period

On August 8, 2020, President Trump signed an executive memorandum (the Memo) directing Treasury Secretary Mnuchin to issue guidance deferring the withholding, deposit and payment by employers of the employee portion of...more

Asset Diversification Test: A Timely Refresher

When a corporation wants to be treated as a regulated investment company (RIC) under the Internal Revenue Code for federal income tax purposes, it must meet certain requirements, including an asset diversification test...more

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