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This blog post describes a situation when there is an exception in the attribution rules so that one spouse is not considered the owner of...

The Tax Cuts and Jobs Act completely rewrote Section 965 to force a one-time repatriation of deferred earnings and profits in foreign corporations. It forces...

Hi from Debra Rudd. ​You are receiving this email because you are signed up for our PFICs Only newsletter, delivered to your electronic mailbox every...

​Hi from Debra Rudd. You are receiving this email because you are signed up for our PFICs Only newsletter, delivered to your electronic mailbox every...

Hello from Debra Rudd. You are receiving this email because you are signed up for our PFICs Only newsletter, delivered to your electronic mailbox every...

Hello from Debra Rudd. You are receiving this email because you are signed up for our PFICs Only newsletter, delivered to your electronic mailbox every...

Hello from Debra Rudd. You are receiving this email because you are signed up for our bi-weekly “PFICs Only” newsletter, delivered to your electronic mailbox...

Hey from Debra Rudd. You are receiving this message because you are signed up for our “PFICs Only” mailing list, delivered to your electronic mailbox...

Hello again from Phil Hodgen, and Happy 2016. Work here We are hiring. You can see the job listings at hodgen.com/jobs. One admin/office manager, one...

Hi from Debra Rudd. You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered to your electronic mailbox every...

Hello from Debra Rudd. You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered directly to your electronic mailbox...

Hello from Debra Rudd. You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered directly to your electronic mailbox...

Hello from Debra Rudd. You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered directly to your electronic mailbox...

Greetings from Debra Rudd. You are receiving this message because you are signed up for our PFICs Only newsletter, delivered to you via e-mail every...

Greetings from Debra Rudd. You are receiving this message because you are signed up for our PFICs Only newsletter, delivered to you via e-mail Thursday...

Hello again from Debra Rudd. This is a weekly newsletter devoted entirely to passive foreign investment companies, sent out every Thursday at 6:00am Pacific time....

Hello from Debra Rudd. This is a weekly newsletter devoted entirely to passive foreign investment companies, sent out every Thursday at 6:00am Pacific time. If...

Hello from Debra Rudd. This is a weekly newsletter devoted entirely to passive foreign investment companies, sent out every Thursday at 6:00am Pacific time. If...

Hello from Debra Rudd. This email is another issue of our PFICs Only mailing list — a weekly publication delivered to your email inbox every...

Greetings from Debra Rudd. You are receiving this email because you signed up for our weekly PFICs Only newsletter. If you would like to cancel...