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In this column, we focus on a particular issue of pressing concern, now that tax and treasury groups at U.S. companies are eagerly eyeing a vast pot of earnings treated as previously taxed income (PTI) by virtue of Code Sec. 965. As practitioners hammer out plans to distribute cash from foreign groups, they are confronted by an unexpected question: is all of this PTI accompanied by sufficient basis to make its distribution truly tax-free?

*This publication was first published at Taxes The Tax Magazine.

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