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2 results on '"Stuardi, Pietro"'

1. Aggregation rules affecting foreign-owned companies

Author

Lawson, Jim, Polizzano, Brad, and Stuardi, Pietro

Subjects
Tax exemption -- Laws, regulations and rules, Tax accounting -- Laws, regulations and rules, Small and medium sized companies -- Laws, regulations and rules -- Taxation, Foreign corporations -- Laws, regulations and rules -- Taxation, Corporate income taxes -- Laws, regulations and rules, Government regulation, Banking, finance and accounting industries, Business, Internal Revenue Code I.R.C. 448(c)
Abstract

Multinational businesses headquartered overseas customarily conduct operations in the United States via local subsidiaries. These U.S. companies, often structured as domestic corporate taxpayers, support their global organizations' efforts in reaching [...]

Published
2023

2. Foreign notional interest regimes may hinder deductions of US subsidiaries

Author

Stuardi, Pietro, Lawson, Jim, Brown, Christopher, and Heroux, Mark

Subjects
Subsidiary corporations -- Taxation, Affiliated corporations -- Taxation, Foreign corporations -- Taxation, Interest deductions -- Laws, regulations and rules, Dividends -- Taxation, Government regulation, Company dividends, Banking, finance and accounting industries, Business, Internal Revenue Code (I.R.C. 245A) (I.R.C. 267A)
Abstract

The recently enacted U.S. anti-avoidance tax rules targeting hybrid mismatches undoubtedly cast a very wide net. The application of these rules poses substantial challenges for global businesses and international tax [...]

Published
2021

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