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Section 245A of the Internal Revenue Code of 1986 (the "Code") effectively exempts U.S. corporations from U.S. Federal income tax on dividends received from certain foreign subsidiaries. ....
Section 245A of the Internal Revenue Code of 1986 (the "Code") effectively exempts U.S. corporations from U.S. Federal income tax on dividends received from certain foreign subsidiaries. ....
Congratulations. Your Israeli start-up is doing well enough for you to consider expanding operations to the U.S. market. Now what? The list of things to think of is endless. ....
When it comes to international tax law, one of the most complicated aspects involves Passive Foreign Investment Companies (PFICs). What makes theā¦ ....