The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or ...
There will be no taxable dividend, then, if a corporation redeems all of its stock owned by an estate. In determining what stock is owned by an estate, the constructive ownership or ...
Preston was a Research Fellow for tax policy in The Heritage Foundation’s Grover M. Hermann Center for the Federal Budget. New IRS regulations require foreign income taxes to adhere more closely to ...
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