AICPA Letter to IRS on Form 4952 Regarding Investment ...

The three categories are: (i) unilateral exemption for passive investment income (i.e., dividends, interest and capital gains from dealings in stocks, bonds and other securities); (ii) reciprocal exemptions for passive investment income either under domestic law or as a result of bilateral tax treaties; and (iii) taxation to the same extent as ... ................
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