U.S. Skeptical About Permanent Safe Harbor for GLOBE Tax Framework
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Controlled Foreign Corporations as Collateral After the TCJA
Kevin M. Cunningham explores situations in which U.S. multinational borrowers might incur a section 956 inclusion as a result of using controlled foreign corporation stock or assets as collateral, and he describes the factors that must be evaluated when providing such collateral as well as the strategies that can be undertaken to avoid the inclusion.
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