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Treatment of deferred foreign income upon transition to participation system of taxation. shareholders of certain specified foreign corporations ( as defined under section 965( e), as amended by P. may have an inclusion under section 965 based on the post- 1986 deferred foreign income of the specified foreign corporations determined as of November 2,, or December 31,. Dear Twitpic Community - thank you for all the wonderful photos you have taken over the years. We have now placed Twitpic in an archived state.
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