Tax Court to address certain important Subpart F sales income issues for the first time

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Cooper Companies could be the first case dealing with the proper application of the foreign base company sales income branch rule, Thus far, no court case or IRS ruling has directly addressed the branch rule. Therefore, the manner in which the Tax Court analyzes and decides the issues could be of significant importance. In addition, regardless of whether the case is ultimately decided or the result, the case presents an opportunity to gain insights about the IRS position on these issues.

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