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U.S.-U.K. Treaty Does Not Exempt U.K. Foundation from U.S.-Source Dividends Tax

March 15, 2010 in Daily Tax Report · Leave a Comment 

The Internal Revenue Service Office of Chief Counsel, in a chief counsel advice memorandum released March 12, said the U.S.-U.K. income tax treaty does not exempt a U.K.-based private foundation from…

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