US tax reform set to increase number of CFCs and transparency risk

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US tax reform set to increase number of CFCs and transparency risk

Lena Angvik
January 22 2018
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The US tax reform introduces changes to Subpart F stock attribution rules that are expected to result in the formation of many new controlled foreign corporations. However, the amendments leave room for interpretation with tax professionals mooting whether the new repatriation and GILTI taxes could also be triggered.

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Lena Angvik worked at ITR between 2016 and 2018
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