Resource Type: Articles

Search Results

954(c)(6) Considerations for 2021

Much has changed since Section 954(c)(6) was enacted in 2005 and getting reacquainted with related party foreign personal holding company income (“FPHCI”) (e.g., dividends, interest,…

Read More

International Tax Planning: BEAT

In order to help organizations navigate key international tax planning considerations during this unpredictable time, GTM is offering a series of updates that can serve…

Read More