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Possession corporations (also known as "936 corporations" could repatriate profits to the United States free of federal taxes after certain stipulated conditions were met or by paying a "tollgate tax" to the possession's government (Pantojas-Garcia 1990: chap.
possession corporations Total Total claiming credit assets receipts (1) (2) (3) All U.
government began reacting, legislatively, to this defect in 1982--with the special measures for possession corporations (Code section 936(h)--and in 1984--with a rule of general application requiring recognition of royalty-type payments over time where intangibles are transferred under section 351 to a foreign corporation (Code section 367(d))--nothing in the Code (even as amended by the super royalty rule) imposes the burden, arising in such circumstances in Canada under section 69 of the Act, of a complete and total taxable disposition.
Possession corporations (also known as "936 corporations") could repatriate profits to the United States free of federal taxes after certain stipulated conditions were met or by paying a "tollgate tax" to the possession's government (Pantojas-Garcia 1990: chap.
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