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45 Int'l Tax J. [i] (2019)

handle is hein.journals/intaxjo45 and id is 1 raw text is: 















     URNAL ..

Wolters Kluwer



)sed Regs

)F CODE SEC. 7874 TO CLARIFY ISSUES REGARDING
FAG E

JS OF FOREIGN CORPORATIONS IN A BRAVE


OCIATED WITH ACCUMULATING AND DISTRIBUTING
RNINGS & PROFITS

fLEDGE AND FBAR PENALTIES: DOES MERELY FILING
-To ESTABLISH WILLFULNESS?

GMENT FROM THE ITALIAN SUPREME COURT ON
ARY DIRECTIVE