Tax Law

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Container Corp. v. Comm’r: Clarity on Guarantee Fee Sourcing?
Posted on 8 Dec 2010 by Rufus Rhoades

Editor's Note : The following is an excerpt from Rhoades & Langer U.S. International Taxation and Tax Treaties § 26.01[3][f] (Matthew Bender). ... The question of how to treat guarantee fees has long vexed both practitioners and the... Read More