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|Journal of Taxation of Global Transactions||Related Party Stock Sales: Recasting Out of Code Sec. 304 Under Rev. Rul. 2004-83||2005|
|CCH Taxation of Global Transactions||Related Party Stock Sales: Recasting Out of Code Sec. 304 Under Rev. Rul. 2004-83”||2005|
|CCH Taxation of Global Transactions||IRS Closes Technical Loophole to Eliminate Foreign Tax Credit Planning with Stapled Stock,||2004|
|CCH Taxation of Global Transactions||CCA Recasts Sale of Partnership Assets to Trigger Subpart F||2003|
|Taxation of Global Transactions||Allocating Foreign Stock Attributes Through Partnerships Under Subpart F — Planners Beware||2002|
|Tax Management International Journal||The Administration’s Corporate Tax Shelter Proposals: What are the Limits of Appropriate Tax Planning||1999|
|Tax Management International Journal||Further IRS Guidance on the Treatment of Section 304 Related Party Sales in the International Setting||N/A|
|Syracuse University College of Law||N/A||N/A||N/A|
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