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Tax Court Decision on Blocked Income
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Overview
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The Tax Court's decision in Coca-Cola v. Commissioner, T.C. Memo. 2023-135, supports the IRS's stance on blocked income tax regulations. This outcome affects $882 million worth of section 482 allocations for tax years 2007 through 2009.
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How could the Tax Court's decision in Coca-Cola v. Commissioner, T.C. Memo. 2023-135, affect other tax cases involving foreign legal restrictions?
How might the outcome of the Coca-Cola case impact the broader taxation landscape?
What are the potential implications of the blocked income regulations on international taxation?
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