The US Treasury and the Internal Revenue Service issued proposed regulations last Thursday providing guidance for determining a US shareholder’s pro rata share of income for controlled foreign corporations (CFCs) under the subpart F rules. The proposed regulations provide detailed rules on distributions of earnings when a CFC has multiple classes of stock. When issued in final form the regulations will be effective for tax years beginning January 1 2005.
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If it gets pillar two right, India may be the ideal country that finds a balance between its global commitments and its national interests, Sameer Sharma argues
The controversial deal would ‘preserve the gains achieved under pillar two’, the OECD said; in other news, HMRC outlined its approach to dealing with ‘harmful’ tax advisers
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