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358 results on '"Foreign source income taxation -- Laws, regulations and rules"'

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1. In defense of Panamanian legal entities.

4. Dressing up the intermediary company.

6. Canada Revenue Agency continues its attack on 'nonresidents'.

7. U.S. expatriates and the offshore crackdown.

8. Rereading U.K. legislation to reflect ECJ decisions.

11. FBAR regulations preserve tax evasion opportunities.

12. U.S. Tax Court allows guarantees for income stripping.

13. Guidance needed for CFC lending transactions.

14. Canada clarifies antihybrid rule in U.S. treaty.

16. Taxing cross-border equity swaps.

17. Japanese business group releases reform proposals.

18. A 'duty' to consider: the new IRS contract manufacturing rules.

20. Qualified intermediary or bust?

22. FBAR filing for trusts.

23. FBAR filing for hedge funds.

27. IRS takes flawed approach to inclusion under subpart F.

29. Vodafone ruling: a close reading of the fine print.

30. Tax reform for Americans abroad.

35. Canada's Prevost decision: the world is watching.

37. A review of the U.S. overall foreign loss rules.

38. Truck Center: a lesson in source vs. residence obligations in the EU.

39. Canadian budget delivers outbound tax relief.

41. A common-sense solution for taxing U.S. citizens and immigrants abroad.

43. U.K. corporate pilgrims: managing in the new world.

44. An analysis of the tax holiday for repatriation under the jobs act.

47. China's tax on expatriate employment income.

48. The debate to come: all eyes on deferral.

50. Reforming Canada's international tax: an interim report.

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