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Senate Fiscal Cliff Bill Includes Retroactive Reinstatement of CFC Look-Thru Rule


Section 323 of the current version of the fiscal cliff bill that passed the Senate last evening includes a retroactive reinstatement of the CFC look-thru rule under Code §954(c)(6).  Under the current version, the CFC look-thru rule would apply for all of 2012 and for 2013.

See section 323 of the Bill

Tags: 951 Subpart F Income, Other - Proposed Legislation