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Analysis

New Tax Law At Odds With Treaties, International Policy

Law360, New York (January 9, 2018, 6:10 PM EST) -- The Republicans’ sweeping tax legislation radically revised the treatment of overseas income in a way that undermines tax treaties at a time when U.S. multinational businesses will need them to resolve cross-border disputes that are on the horizon, specialists say.

H.R. 1, previously known as the Tax Cuts and Jobs Act, which President Donald Trump signed on Dec. 22, retools the international tax system and will exempt most of a U.S. company's foreign profits from taxation after it brings home its currently deferred offshore income at...
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