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Court Sustains European Commission’s Meddling in Transfer Pricing
By Lee Sheppard
In news analysis, Lee A. Sheppard examines the Starbucks and Fiat state aid cases, both decided by the General Court of the European Union, asking how to reconcile the different outcomes
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TCJA Corrections: Some Technical, Some Not
By Mindy Herzfeld
In the second in a series reviewing provisions that could be included in upcoming tax legislation, Mindy Herzfeld looks at recent proposals to address both extenders and technical corrections to the Tax Cuts and Jobs Act.
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Hypothetical Distribution, Part 2: Determining Pro Rata GILTI Items
By Carrie Brandon Elliot
Carrie Brandon Elliot reviews how hypothetical distribution rules for determining pro rata shares of subpart F income are modified to determine pro rata shares of GILTI items.
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