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California Seeks to Limit Net Operating Losses

From the enactment of the Tax Cuts and Jobs Act of 2017 (TCJA), California was one of the handful of states that did not conform to a number of provisions in the law. Most notably, the state continued to allow taxpayers to take full advantage of the net operating loss (NOL) deduction and ignore 80% ...

United States Income Tax Treaties That Meet the Requirements of Section 1(h)(11)(C)(i)(II)

IRS released Notice 2024-11 on December 28, 2023, updating the list of countries with tax treaties meeting Section 1(h)(11)(C)(i)(II) criteria. Under section 1(h)(11) (qualified dividends), a dividend paid to an individual shareholder from either a domestic corporation or a "qualified foreign ...

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