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Transactions with foreign corporations reduce possessions tax credit

|Approved Changes|United States; Puerto Rico
United States; Puerto Rico

The US District Court for the District of Puerto Rico has held that a US corporation is required to reduce the cap on the possessions tax credit under section 936 of the US Internal Revenue Code (IRC) when it transfers a major portion of its businesses to a foreign corporation. Pharmaceuticals, Inc., v. United States, Civil No. 11-1312 (GAG) (10 October 2012).
The case involved a US corporati…

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