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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,…

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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…

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