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Antoinette Luchini

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International Tax Update: OECD Releases Latest Edition of Model Tax Convention

On April 25, the Organisation for Economic Co-operation and Development (OECD) formally released the tenth edition of its Model Tax Convention on Income

Application to Receive Funding for On-Road and Class 8 Fleet Vehicle Projects in Pennsylvania Now Available!

As you know from our previous articles (Volkswagen Environmental Mitigation Trust Fund), Volkswagen is obligated to fund various environmental trusts for

Transfer Pricing: A Reporting Requirement for Multinational Corporations

It should come as no surprise that large companies often create affiliate and/or subsidiary companies to carry out various parts of their operations across

Effective Dividends to Receive a 100% Deduction under New Proposed Treasury Regulations

It should come as no surprise that taxpayers seek to minimize tax liability and maximize tax benefit. One way to achieve that result is for taxpayers to

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An Inflow of Opportunity: Tax-Free Repatriation of Foreign Source Income from a Controlled Foreign Corporation

For more than fifty years, and subject to many exceptions, U.S. shareholders have been utilizing the controlled foreign corporation (“CFC”)

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