On the recordSeptember 19, 2012
The facts and circumstances of each case must be reviewed to determine if, in substance, there has been a repatriation of the earnings of the controlled foreign corporation.
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congress.govCarl Levin: “The facts and circumstances of each case must be reviewed to determine if, in substance, there has been a repatriation…”
Editor's note · Context
Discussing the criteria for repatriation of earnings in tax law.
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