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Memorandum: Overview of the Principal Provisions of Jobs Act

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TO:Clients & Friends of the Firm
FROM:The Ruchelman Law Firm*
RE:Overview of the Principal Provisions of Jobs Act
DATE:December 9, 2004

We are pleased to provide this overview of the international tax provisions of the American Jobs Creation Act of 2004 (the Act) signed by the President and entered into force on October 22, 2004. Many comments have been made regarding provisions of the Act, noting both technical provisions and open issues. We trust this overview provides insight into the thought process that can be employed by U.S.-based multinational corporations and foreign investors in the U.S. in prioritizing strategies to deal with the Act’s provisions.