| 1 |
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Consolidated Group Members Become Single Under GILTI
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Elliot, Carrie Brandon
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Tax Analysts
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2019
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| 2 |
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Consolidated Groups Face Challenges From Proposed 163(j) Regs
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Elliot, Carrie Brandon
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Tax Analysts
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2019
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| 3 |
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Consolidated Groups Seek Deductions Under Proposed FDII and GILTI Regs
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Elliot, Carrie Brandon
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Tax Analysts
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2019
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| 4 |
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Consolidated Groups Still Facing Hybrid and DCL Problems
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Elliot, Carrie Brandon
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Tax Analysts
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2019
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| 5 |
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Consolidated Groups Weigh GILTI Effect on Basis Adjustments
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Elliot, Carrie Brandon
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Tax Analysts
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2019
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| 6 |
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Consolidated Groups Wrestling With the BEAT
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Elliot, Carrie Brandon
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Tax Analysts
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2019
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| 7 |
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Election to Consolidate Can Affect Transition Tax Liability
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Elliot, Carrie Brandon
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Tax Analysts
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2019
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| 8 |
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Expanding Hybrid Deduction Accounts To GILTI and Subpart F
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Elliot, Carrie Brandon
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Tax Analysts
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2019
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| 9 |
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Extending Section 267A To Reverse Hybrids
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Elliot, Carrie Brandon
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Tax Analysts
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2019
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| 10 |
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Foreign Investor Real Estate Tax Exemption Hits U.S. Tax Base
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Elliot, Carrie Brandon
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Tax Analysts
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2019
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| 11 |
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How Section 245A Temporary Regs Limit Dividends Received Deductions, Part 2
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Elliot, Carrie Brandon
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Tax Analysts
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2019
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| 12 |
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How Sections 245A and 964(e)(4) Coordinate Treatment of Dividends
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Elliot, Carrie Brandon
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Tax Analysts
|
2019
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| 13 |
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How the Tax Code Opens U.S. Politics To Foreign Nationals
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Elliot, Carrie Brandon
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Tax Analysts
|
2019
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| 14 |
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Hybrid Regulations: Overreach or Underdone?
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Elliot, Carrie Brandon
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Tax Analysts
|
2019
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| 15 |
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Hypothetical Distribution, Part 2: Determining Pro Rata GILTI Items
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Elliot, Carrie Brandon
|
Tax Analysts
|
2019
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| 16 |
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Hypothetical Distributions, Part 1: Determining Pro Rata Subpart F Income
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Elliot, Carrie Brandon
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Tax Analysts
|
2019
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| 17 |
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Income Classification Reaches Digital Content and Cloud Computing
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Elliot, Carrie Brandon
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Tax Analysts
|
2019
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| 18 |
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Navigating TCJA Foreign Tax Credit Limitations
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Elliot, Carrie Brandon
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Tax Analysts
|
2019
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| 19 |
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New Regs Ease Double Counting and Mismatches
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Elliot, Carrie Brandon
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Tax Analysts
|
2019
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| 20 |
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Preventing Double Nontaxation: Subpart F and GILTI Coordination
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Elliot, Carrie Brandon
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Tax Analysts
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2019
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