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The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.

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Recent Articles


How Section 245A Temporary Regs Limit Dividends Received Deductions

Tax AnalystsBy Carrie Brandon Elliot

Carrie Brandon Elliot reviews how new section 245A temporary regulations curtail section 245A’s participation exemption for distributions of E&P earned after the transition tax final measurement date but before the effective date of GILTI.

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By Carrie Brandon Elliot, posted on Friday August 9, 2019

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