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US Repatriation of Foreign Earnings

Gregg D Lemein, Stewart R Lipeles, John D McDonald and Jefferson VanderWolk, Partners, Baker & McKenzie, write on the new US legislation on tax-advantaged repatriation of foreign earnings

 
Gregg D Lemein Stewart R Lipeles John D McDonald and Jefferson VanderWolk Partners Baker & McKenzie write on the new US legislation on tax-advantaged repatriation of foreign earnings
 
In last week's article (The Tax Journal 28 February 2005 Issue 778) we discussed the requirements of new s 965 of the US Internal Revenue Code which provides for a dividends-received deduction (DRD) in respect of a cash dividend from a controlled foreign corporation (CFC) to a US corporate shareholder. Essentially the taxpayer can deduct 85% of cash dividends from CFCs during a one-year period elected...

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