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TAX CLINIC
Practical advice on current issues.
Editor:
Alexander J. Brosseau, CPA In This Department
CORPORATIONS & FOREIGN INCOME &
SHAREHOLDERS TAXPAYERS
New stock repurchase excise tax; Corporate AMT: Unanswered
p. 7. questions about its foreign tax
credit; p. 18.
CREDITS AGAINST TAX
The research credit: Funded PRACTICE &
research; p. 11. PROCEDURES
More than three dozen IRS letter
EXPENSES & rulings allow late QOF
DEDUCTIONS self-certifications; p. 22.
Uncertainties remain in analyzing
success-based fees; p. 15. PROCEDURE &
ADMINISTRATION
Protecting contingent refund
claims; p. 26.
Unless otherwise noted, contributors This publication contains general information only and Deloitte is not, by means of this
are members of or associated with publication, rendering accounting, business, financial, investment, legal, tax, or other
Deloitte Tax LLP. professional advice or services. This publication is not a substitute for such profession-
al advice or services, nor should it be used as a basis for any decision or action that
For additional information about may affect your business. Before making any decision or taking any action that may IMAGE BY PIXEL_DREAMS/ISTOCK
these items, contact Mr. Brosseau affect your business, you should consult a qualified professional adviser. Deloitte shall
at 202-661-4532 or abrosseau@ not be responsible for any loss sustained by any person who relies on this publication.
deloitte.com.
6 March 2023 The Tax Adviser