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Introduction

SECTION 6. COMMENTS

Internal Revenue Bulletin 2008-3 · 2026-10-03 edition · updated 2026-10-04 · United States

The IRS and Treasury are studying other transactions and structures that have the effect of repatriating earnings of foreign corporations without the recognition of gain or a dividend inclusion. Comments are requested in this regard. Comments are also requested regarding more fundamental changes that can be made in this area, including possible changes to the coordination rule.

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▸Contents — Internal Revenue Bulletin 2008-3
Internal Revenue Bulletin 2008-3

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