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Posted on December 06, 2013 in 1291 PFICs, 482 Transfer Pricing, 901 Foreign Tax Credits, 991 IC DISC, Authority - PLRs / CCAs, Form 8621 | Permalink
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Posted on November 02, 2013 in 1(h)(11) Qualified Dividend Income, 701 Partnerships, 861 Source of Income, 894 Limitation on Benefits, 894 Treaties, 991 IC DISC, Authority - PLRs / CCAs, Country - Canada, Form 8891 | Permalink
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Posted on September 06, 2013 in 901 Foreign Tax Credits, 991 IC DISC, Authority - PLRs / CCAs, Country - Canada, Form 8891 | Permalink
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Posted on September 05, 2013 in 991 IC DISC, Authority - PLRs / CCAs, Country - Canada, Form 8832, Form 8891 | Permalink
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Posted on March 22, 2013 in 991 IC DISC, Authority - PLRs / CCAs | Permalink
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Posted on February 01, 2013 in 7701-3 Check-the-Box Elections, 991 IC DISC, Authority - PLRs / CCAs, Form 8832 | Permalink
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Posted on January 26, 2013 in 991 IC DISC, Authority - PLRs / CCAs | Permalink
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Posted on November 05, 2012 in 351 Exchanges, 7874 Corporate Inversions, 991 IC DISC, Authority - PLRs / CCAs, Country - Canada, Form 8891 | Permalink
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Posted on September 15, 2012 in 991 IC DISC, Authority - PLRs / CCAs, Country - Canada, Form 8891 | Permalink
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Posted on June 16, 2012 in 7701-3 Check-the-Box Elections, 991 IC DISC, Authority - PLRs / CCAs, Country - Canada, Form 8832, Form 8891 | Permalink
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Posted on June 11, 2012 in 991 IC DISC, Authority - PLRs / CCAs | Permalink