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Single-entity treatment of consolidated groups - KPMG United States
Webinclusion subpart F income is taxed solely under Section 951, whereas de minimis subpart F income is taxed solely under Section 951A. Under the Final Regulations, however, full inclusion income excluded from subpart F income by reason of Treas. Reg. sec. 1.954-1(d)(6) (exception to the full inclusion rule for high-taxed Web8 Apr 2024 · Case 2:22-cv-00223-Z Document 137 Filed 04/07/23 Page 21 of 67 PageID 4443 of Navy, 757 Fed. Appx. 172, 175 (3d Cir. 2024) (a petition for reconsideration can restart Section 2401(a)'s limitation ... fly cruise japan 2024
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