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Controlled Foreign Corporations Compliance

Final Regulations Partially Mitigate Overbroad Controlled Foreign Corporation Attribution Rules Passed as Part of 2017 U.S. Tax Reform

The U.S. Internal Revenue Service (“IRS”) recently finalized tax regulations under its complex controlled foreign corporation (“CFC”) regime that partially mitigate some of the harsh tax consequences resulting from an apparent drafting error contained in the 2017 U.S. tax reform legislation. The 2017 US tax ...
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The member firms of Andersen in Canada focus on Canadian, international and Canada-U.S. cross-border tax matters. With offices across Canada, our tax professionals work with a broad range of businesses and individual clients to develop innovative tax solutions for a diverse range of issues. Our senior leaders and many of our professional staff have extensive experience in Canadian, international, U.S. and cross-border tax matters with major international accounting firms, as well as practical experience working with businesses and individuals.