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Expert Analysis

Investment Cos. And REITs Receive Welcome Tax Guidance

By Martin Hamilton, Timothy Donovan and Martine Seiden Agatston (September 24, 2018, 5:03 PM EDT) -- On Sept. 6, the Internal Revenue Service released Revenue Procedure 2018-47, which provides that a repatriation deemed to have been received by a registered investment company, or RIC, under Section 965 (enacted as part of the 2017 tax reform act commonly known as the "Tax Cuts and Jobs Act") is treated as a "specified gain." As a result, the amount of the deemed repatriation need not be distributed by the RIC until 2018 in order for the RIC to avoid the 4 percent excise tax imposed under Section 4982(a)....

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