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

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Foreign Tax Credit Recapture and Schedule UTP

  • By Lee A. Sheppard

Lee A. Sheppard examines the foreign tax credit recapture and Schedule UTP aspects of Liberty Global and details why the Tax Court rejected Liberty Global’s argument that its capital gain in excess of its overall foreign loss should be exempt from U.S. tax.

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