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GILTI Figures Into CFC Applicability Project, Official Says

By David van den Berg (March 19, 2024, 6:15 PM EDT) -- The U.S. global intangible low-taxed income system is factoring into continuing Internal Revenue Service work on whether a tax code provision limiting corporations from offsetting income with net operating or other tax losses after ownership changes applies to controlled foreign corporations, an agency official said Tuesday....

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