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To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or tax-related matter(s) addressed herein.

This blog is personal, reflects my own views and not the views of my employer, and has not be reviewed by my employer for completeness or accuracy.

Wednesday, February 23, 2011

SubChapter M Tax: qualifying income under 851(b)(2) from a Controlle...

SubChapter M Tax: qualifying income under 851(b)(2) from a Controlle...: "qualifying income under 851(b)(2) from a Controlled Foreign Corp - IRS Private Letter Ruling 201049015 This responds to your letter dated Ap..."
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