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News and Updates

So You own a CFC, What Now?

In our whitepaper, The Expansion of “United States” Taxpayers: How...

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Stage Five Clinger: How the TCJA Latches onto Unassuming Foreign Personsthrough Constructive Ownership

In our whitepaper, The Expansion of “United States” Taxpayers: How...

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Part Three of the TCJA Attribution Rules: Down the Rabbit Hole

In our blog post titled “Owning” Shares that aren’t Yours:...

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