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U.S. Skeptical About Permanent Safe Harbor for GLOBE Tax Framework

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Company Challenges Reg for Ignoring Downward Attribution Change

  • By Andrew Velarde

In Solar New US Holding Corp. v. Commissioner, a Tax Court challenge that could have implications for other rules, a company argues that the statutory repeal of the downward attribution exception makes the definition of a controlled foreign corporation under anti-inversion regulations invalid.

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