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Second Circuit Summarily Affirms in Barnes

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The Second Circuit did not make the parties wait very long to learn the outcome of the Barnes Group’s appeal from the Tax Court’s imposition of dividend treatment on its multi-step transaction that enabled it to use in the United States cash that was located in Singapore.  See our prior reports here and here.  Little more than a month after oral argument, the court of appeals today issued a summary order affirming the Tax Court in all respects.  The first page of such unpublished orders recites that they “do not have precedential effect,” but they can be cited in … Read More


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