§14103

1 cases·1 cited

Statute text not available for this section.

1 Citing Cases

at 2195–208 (codified at I.R.C. § 965); see also Moore, 144 S. Ct. at 1686. The MRT generally required that certain accumulated foreign earnings held by CFCs, but not repatriated to the U.S. shareholders, be included in the U.S. shareholders’ subpart F income and taxed at a lower-than-normal rate. See TCJA § 14103, 131 Stat. at 2

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