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From:
U.S. Citizens and Green Card Holders Residing in Canada and Abroad
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Take YOUR Money And Run: Understanding The Proposed § 899. ENFORCEMENT OF REMEDIES AGAINST UNFAIR FOREIGN TAXES - U.S. Citizens and Green Card Holders Resid...
http://citizenshipsolutions.ca/2025/05/20/take-your-money-and-run-understanding-the-proposed-§-899-enforcement-of-remedies-against-unfair-foreign-taxes/
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Big Beautiful Bill Includes Penalty Taxes imposed on tax residents of discriminatory countries.