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Foreign Corporations

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U.S. Department of Treasury’s Proposed PTEP Regulations: Key Changes and Tax Implications

Fenwick & West LLP on 2/6/2025

The U.S. Department of Treasury (Treasury) recently released proposed regulations under §§ 959 and 961 and related Code sections (REG-105479-18, the “Proposed Regulations”) addressing the treatment of previously taxed...more

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Internal Revenue Code (IRC) › Proposed Rules › Foreign Corporations

U.S. Department of Treasury’s Proposed PTEP Regulations: Key Changes and Tax Implications

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