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Tax Assessment Section 956

Fenwick & West LLP

Recent Tax Court Decision in Crestek – a Cautionary Tale for U.S. Companies with Foreign Subsidiaries

Fenwick & West LLP on

In a ruling with tax implications for U.S. corporations with foreign subsidiaries, the U.S. Tax Court has held that transactions between a U.S. parent company and its controlled foreign corporations constitute “United States...more

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