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David E. Kahen and Elliot Pisem, membersof Roberts & Holland, write that a recent appellate ruling underscores the need for U.S. advisors to a foreign corporation engaged or deemed engaged in a U.S. trade or business, even a corporation that regularly incurs losses and appears to have no U.S. tax liability, to be alert to the requirement that the corporation timely file U.S. returns, at least in part so as to preserve deductions that may otherwise be lost.
April 17, 2008 at 12:00 AM
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