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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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IRS Trying to Coordinate GILTI and Participation Exemption Rules

Tax AnalystsBy Ryan Finley

IRS officials are aware of the possibility that antiavoidance provisions of the global intangible low-taxed income and participation exemption regulations could create double gain recognition and are looking for appropriate ways to avoid that result.

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By Ryan Finley, posted on Saturday September 7, 2019
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