Michael Karlin was published in the Journal of International Taxation with an article entitled, “Virtual Withholding: Expanding the Observable Universe of Withholding.” He explores the complexities and nuances of withholding tax regulations, particularly in situations where tax is imposed even when there is no immediate payment – delving into scenarios such as income imputation in the context of transfer pricing or below-market loans, income arising from the cancellation of debt, and unexpected income from securities lending or sale-repurchase transactions.
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