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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

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”)

Increased Penalties for Failure to File an FBAR to Report Foreign Financial Assets

The Financial Crimes Enforcement Network (FinCEN) recently announced inflation-adjusted penalties for failure by U.S. persons to file a Report of Foreign

NIST Releases Final Draft Publication to Assist in Assessing Compliance with NIST SP 800-171

Background As of December 31, 2017, all Department of Defense (DoD) contractors that process, store or transmit Controlled Unclassified Information (CUI)

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GDPR: Common Myths and Truths Revealed

The General Data Protection Regulation (GDPR) has been a hot topic of conversation since being adopted in April 2016. The new regulation changes how companies

Reminder: Foreign-owned U.S. Disregarded Entities Face New Reporting Requirements

Until recently, disregarded entities (DREs) were typically not required to obtain an employer identification number (EIN) and generally did not have federal

TPP Likely To Pass Without U.S.

This month the 11 remaining countries in negotiations under the Trans-Pacific Partnership (TPP) signaled that the agreement will move forward under a new

IRS Issues Notice for Computing "Transition Tax"

On December 29, the Internal Revenue Service (IRS) and Treasury Department published Notice 2018-07 (Notice), providing guidance for computing the “transition

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Tax Reform Series: International Tax Implications from the House and Senate Tax Bills

This month, the U.S. House of Representatives and Senate both released proposed laws looking to dramatically reform taxation in America. On November 16,

UK Country-by-Country Reporting Notification Due September 1

For large businesses operating in the UK, the first country-by-country (CbC) reporting notification is due to Her Majesty's Revenue and Customs (HMRC)

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