When does a short swap toll a shareholder's holding period for stock?

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The regulations provide guidance on the withholding requirements for transfers of partnership interests by foreigners.

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The last part of our four-part examination of the OECD Base Erosion and Profit Shifting Project looks at how jurisdictions have responded.

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What can we learn from the UK High Court's interpretation of the words “subject to taxation” in a contractual tax gross-up clause?

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