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  • ACLI Update
    Model Rules acknowledges the goal of qualifying the U.S. Global Intangible Low-Taxed Income (GILTI) rules ... lead to the recognition of gains (or losses) … for U.S. income tax purposes and to correspondingly potentially ...

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    • Authors: Regina Y Rose
    • Date: Feb 2022
    • Competency: Technical Skills & Analytical Problem Solving
    • Topics: Finance & Investments; Finance & Investments>Investments; Public Policy; Public Policy
  • Treasury Issues Proposed Rules for Determining Active Income of Certain Foreign Insurance Companies
    introduced to prevent U.S. persons from obtaining indefinite deferral of U.S. tax on investment income ... activities. Under the PFIC rules, certain minority U.S. shareholders of foreign entities deemed to be passive ...

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    • Authors: Jay Riback, Jean Baxley
    • Date: Feb 2020
    • Competency: Strategic Insight and Integration; Technical Skills & Analytical Problem Solving
    • Publication Name: Taxing Times
    • Topics: Finance & Investments; Finance & Investments>Investments; Financial Reporting & Accounting; Financial Reporting & Accounting>Tax accounting