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Law360 Quotes Clark Armitage: Tax Laws' Avoidance Rules Could Entangle Foreign Deals

June 4, 2018, Law360

In a provision meant to target mobile income from patents stashed in tax havens, the federal tax overhaul's anti-avoidance measures may greatly complicate some foreign acquisitions and sales, according to practitioners.

. . .

In the case of corporate sales, the one-time income gain could push an entity above the 10 percent threshold and entangle it in the GILTI rules, even if it normally falls below them.

"You could view it as the acceleration of future gains you might have earned," said Clark Armitage, of Caplin & Drysdale in Washington, D.C.

To view the full article, please visit Law360’s website (subscription required).

Excerpt taken from the article “Tax Laws' Avoidance Rules Could Entangle Foreign Deals” by Alex M. Parker for Law360.


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