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Note and Disclaimer to the User:

These documents are whitepapers predominantly dealing with tax issues. They were prepared for use by one or more of our attorneys, or their present or former colleagues, in educational presentations delivered to lawyers, other professionals, clients, and friends. They are presented for your use and review in gaining an understanding of the substantive areas addressed and to provide insight into our various areas of expertise.  They cannot and should not be relied on by anyone as legal or tax advice. Be warned that, particularly with regard to tax sensitive presentations, the date of preparation and presentation is key since later law changes could drastically and adversely affect the accuracy of the materials.  This is particularly true given the recent enactment of the Tax Cuts and Jobs Act of 2017 (Pub. L. No. 115-97) ("TCJA") which effected monumental changes in the taxation of cross-border transactions and structuring from a U.S. tax perspective and otherwise made significant and far-reaching changes to federal income tax law.