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United States | New IRC Section 899 would increase tax rates and expand BEAT for certain inbound taxpayers

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United States

  • New IRC Section 899 would increase applicable tax rates and expand base erosion and anti-abuse tax (BEAT) rules on foreign persons tax resident in, or controlled by tax residents of, "discriminatory foreign countries."
  • The Bill would have broad reach and apply to certain individuals, foreign governments, foreign corporations, private foundations, certain trusts, and certain foreign partnerships of …

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