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Supreme Court Holding Adds Complexity to Estate Planning

Keeping it in the family just got more complicated. Our Tax Group studies a Supreme Court decision that left a family with an unexpected estate tax liability related to a share redemption agreement....more

Letter Ruling Conjures Ghost of Section 958(b)(4) Past

The Tax Cuts and Jobs Act of 2017 continues to reverberate even unto the end of 2020. Our International Tax Group discusses a letter ruling that may have been a harbinger of proposed regulations to address exceptions to...more

Treasury’s High Wire Act – Final and Proposed Regulations on CFC High-Tax Exceptions

Our International Tax Group examines the high-tax exclusion (HTE) in new final regulations under the global intangible low-taxed income (GILTI) regime and the potentially precarious side effects U.S. shareholders face in...more

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