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49 Int'l Tax J. [i] (2023)

handle is hein.journals/intaxjo49 and id is 1 raw text is: 















OURNA

)y Wolters Kluwer



on a Mid-Year PTEP Distribution

THEIR LIMITS ON THE PRO RATA SHARE RULE OF CODE


JS OF COMPANIES INVESTING IN PARTNERSHIPS: WHICH


DUND ECONOMIC SUBSTANCE DOCTRINE WARRANT
RATION

)RE IRS ENFORCEMENT OF REPATRIATION /TRANSITION


THAT FIRMS AND TAx ADMINISTRATIONS (THE LATTER,
LITIGATE IN TRANSFER PRICING

ADVANCED PRICING AGREEMENTS ARE CONTRACTS