Pending Regulatory Challenges to Select International Provisions of the Tax Cuts and Jobs Act
Pending Regulatory Challenges to Select International Provisions of the Tax Cuts and Jobs Act
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Williamsburg: College of William and Mary, Marshall-Wythe School of Law
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English
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Williamsburg: College of William and Mary, Marshall-Wythe School of Law
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The section 245A temporary regulations were issued to address a "mismatch" between the effective dates of two key international provisions of the TCJA intended to facilitate the move to a territorial system-the dividends-received deduction under section 245A and the global intangible low taxed income tax under section 951A-and are challenged on bot...
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Pending Regulatory Challenges to Select International Provisions of the Tax Cuts and Jobs Act
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TN_cdi_proquest_journals_2619675684
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https://devfeature-collection.sl.nsw.gov.au/record/TN_cdi_proquest_journals_2619675684