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Keywords: interest
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Journal Articles
The ATA Journal of Legal Tax Research (2013) 11 (2): 86–101.
Published: 01 August 2013
... policy. The reward structure requires an accountable use of the repatriated funds for designated investments that further the economic needs goals of the U.S. Under our proposal, an interest charge would be assessed on unrepatriated offshore profits and would be reduced as various remission targets...
Journal Articles
The ATA Journal of Legal Tax Research (2013) 11 (2): 38–52.
Published: 01 July 2013
...John Gamino ABSTRACT This paper explores Internal Revenue Code (IRC) section 6404(e)(1). Enacted in 1986 and amended in 1996, this section authorizes the Internal Revenue Service (IRS) to abate assessed interest on tax deficiencies and underpayments to the extent attributable to prescribed...